These questions are referred to as "Interrogatories". IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. 0000037811 00000 n "Exclusive arrangement with a dental laboratory or dentist" means any proposed or actual agreement, arrangement, policy, program, practice, term or condition of your company that: a. requires any dental laboratory or dentist to limit the use of, or refrain from using, the products of any other person; or. Sample Interrogatories in Personal Injury and Malpractice Cases. Form A (2) - Uniform Interrogatories to be Answered by Plaintiff in Product Liability Cases (Other Than Pharmaceutical and Toxic Tort Cases) Only: Superior Court Form B - Uniform Interrogatories to be Answered by Plaintiff: Property Damage to Motor Vehicle: Superior Court* Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. Unless otherwise specified, the information called for by these interrogatories is limited in scope to information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in the United States. The form must be signed by the firm's Contact Person prior to submitting. A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . R. Civ. Pursuant to Fed. N.J.R. COURTS on-line Subscriber Change Form(fillable): this form needs to be completed if an existing COURTS on-line subscriber has had a change to their name or e-mail address or if their e-filing access level request has changed. (fillable), Order Approving Settlement under NJSA 34:15-20:(fillable) (page 1 and 2), Order for Distribution (for child support), Order for Distribution of Temporary Award (for child support), Affidavit of Dependent in Support of Settlement Under N.J.S.A. So both the client and the lawyer are usually involved in preparing these written responses. 17. L-3773-15. Complaint for Divorce (with children) Complaint for Divorce (without children) Certification of Insurance (filed with Complaint and Answer) Confidential Litigant Information Sheet (filed with Complaint and Answer) Answer and Counterclaim. SUPERIOR COURT OF NEW JERSEY. 0000007135 00000 n But the total number of requests cannot exceed thirty. State your full name, your present address, and date of birth. The best advice for propounding, answering and following up on interrogatory answers is the one thing that few attorneys do: put thought into them as to exactly how you are going to use them at trial. 1. Objections to Interrogatories, Rule 4:17-6. 30 0 obj <> endobj Pursuant to Fed. Please read through these Interrogatories and prepare your responses, this will save you time Think about the hard questions that you would like to get answers to read to a jury. CERTIFICATE OF SERVICE. e. in the case of an agreement, its date, the place where it occurred, the identity of all persons who were parties to the agreement, the identity of each person who has knowledge of the agreement and all other persons present when it was made, and the subject matter of the agreement. A. 2 0 obj (Update: Yep, that is what happened!). THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. Don't object just because you don't want to answer the question and try to keep the objection as narrow as possible. District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. P. 26(e), you are under a duty seasonably to amend any answer to these interrogatories for which you learn that the answer is in some material respect incomplete or incorrect and if the additional or corrective information has not otherwise been made known to us during the discovery process or in writing. Hurley v. The Atlantic City Police Pursuant to Tennessee Rule of Civil Procedure 26.02(5), if any It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline. But the pursuit is worth getting proper and complete answers. %PDF-1.5 First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. Google Translate is an online service for which the user pays nothing to obtain a purported language translation. Your landlord must respond to these requests under oath; they are then admissible in court if you need them. Think about the case individually. 20. Sample Interrogatories From Defendants Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. These are sample written questions that you might receive in your divorce. Princeton, New Jersey 08542-0627 Tel. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). "Including" means including, but not limited to. Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. endobj %PDF-1.5 % Interrogatories Definition: Written questions submitted to a party from his or her adversary to ascertain answers that are prepared in writing and signed under oath and that have relevance to the issues in a lawsuit. When practicing family law here in New Jersey, one of the most fact sensitive areas for an attorney to handle is a child custody case. INTERROGATORIES TO PLAINTIFF Ans. 2. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. 8/9/97 1. Any challenge to the certification of due diligence will be deemed waived unless brought by way of motion on notice filed and served within 20 days after service of the amendment. The term "or" shall mean "and" and vice-versa, as necessary to bring within the scope of the following interrogatories all information or documents that would be excluded absent this definition. Follow instructions on the form. previous. 2. Make your practice more effective and efficient with Casetexts legal research suite. Pursuant to Fed. 7. Don't take the insurer's set of written interrogatories lightly. See, R. 4:17-4(a). Hb```f`` uuid:984c0652-48fa-4f55-badd-b9b174a742c7 responses to first set of interrogatories ELECTRONICALLY FILED - 2018 Mar 15 2:01 PM - GREENVILLE - COMMON PLEAS - CASE#2014CP2304432. Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. 21. If you have any questions about New Jersey contract law and contract litigation, then please contact Fredrick P. Niemann, Esq. DOCKET NO. 0000002626 00000 n Service, Scope of Interrogatories (a) Generally. Ask defendants the hard questions and ask them early in the case to pin them down (and to have time to file a motion to compel when they don't give complete answers). "Dental laboratory" means any person that prepares, constructs, assembles or otherwise fills an order or prescription from a dentist for dentures or any other removable or fixed dental prosthetic device, and includes any group, chain or organization of dental laboratories. The most classic objection is that the interrogatory asked is objectionable under Maryland law because it is "vague, burdensome, overly broad, and not reasonably calculated to lead to admissible evidence." Very early on during into the case, our lawyers are sure to prepare our clients for the types of questions they shall face not only in a child custody plenary hearing (i.e., trial), but even before the trial begins. Unless you go over every answer - and even interrogate them just a little bit - there is a chance you are going to get it wrong. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. Many use this objection to the simplest of questions. Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) hbbd``b` $c`b - V0P2$30RNg Sample Interrogatories Posted on March 11, 2010 by Neil Garfield A special thanks to Neil Garfield for all the great research and work he has done and continues to do, to help homeowners fight to save their homes from foreclosure fraud. The list below contains the sample NJ divorce documents discussed above. Washington, DC 20005 . Focusing just on this is better than reading a thousand different articles on developing discovery. Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action. Questions About Marriage and Marital History. Interrogatories may, without leave of court, be served upon the plaintiff or answers demanded pursuant to R. 4:17-1(b) after commencement of the action and served upon or demanded from any other party with or after service of the summons and complaint upon that party. As suggested above, you will often get this response even when you using template questions employed by the court. 39 0 obj <>/Filter/FlateDecode/ID[<3DE8017F54D98D5939ED3FFC60811FA0><341CF33D3F5EAB49B7E5710A1889DF18>]/Index[30 26]/Info 29 0 R/Length 62/Prev 47862/Root 31 0 R/Size 56/Type/XRef/W[1 2 1]>>stream 73 0 obj <> endobj 74 0 obj <> endobj 265 0 obj <>stream Comments and Help with example of sample interrogatories divorce CIVIL CONVICTION STATUS The following persons: (1) Have been convicted of any felony and, at the time of making the application, did not have a "strike" pursuant to G.S. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. Call us today at (856) 685-7420 to schedule a free consultation. If you think you need an extension to answer, ask for it early. INTERROGATORIES 1. HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 55 0 obj <>stream Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. and CONSTANCE COLEMAN, Plaintiffs-Appellants, . For any record or document responsive or relating to these interrogatories which is known to have been destroyed or lost, or is otherwise unavailable, identify each such document by author, addressee, date, number of pages, and subject matter; and explain in detail the events leading to the destruction or loss, or the reason for the unavailability of such document. These are INTERROGATORIES RELATING TO JURISDICTIONAL DISCOVERY Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Smithfield Foods, Inc. ("SFD") states its responses and objections to Plaintiff's First Set of Interrogatories Relating to Jurisdictional Discovery ("Interrogatories") as follows: GENERAL OBJECTIONS 1. The term also includes information stored in, or accessible through, computer or other information retrieval systems (including any computer archives or back-up systems), together with instructions and all other materials necessary to use or interpret such data compilations. R. Civ. But if the question is overly broad, vague, privileged, or not relevant, you should object. Number of Copies Served; Form of Interrogatories. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 14. The case settled and I got a lot more money than I expected. All questions must be answered unless the court otherwise orders or unless a claim of privilege or protective order is made in accordance with R. 4:17-1(b)(3). "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth. 8/22. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE Sample interrogatories for counsel to use in cases pending in the New Jersey Superior Court, Law Division, Civil Part or Chancery Division, General Equity Part. "Communication" means any disclosure, transfer, or exchange of information or opinion, however made. State: (a) the full name and residence address of each defendant . I understand that submitting this form does not create an attorney-client relationship. The responding party must answer in writing and under oath. at fniemann@hnlawfirm.com or call him toll-free at (855) 376-5291. 0000001829 00000 n "Year" means calendar year or the twelve-month period on which your business records are based; if the latter is used in responding to a interrogatory, specify the twelve month period used. Case Management Order. Download Sample Answer To Interrogatories New Jersey: FileName Speed Downloads Sample Answer To Interrogatories New Jersey [Most popular] 5288 kb/s 1996 Sample Answer To Interrogatories New Jersey | NEW 4174 kb/s 4237 Sample Answer To Interrogatories New Jersey | checked 3591 kb/s 7820 Sample Answer To Interrogatories New Jersey 5834 kb/s 7593 The process adds layers of time, expense and tedious effort because a motion must be drafted and typically the judge will require the lawyers to attend a hearing on the motion. Get a copy to your clients quickly. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> *266 Mr. David A. Rappeport, attorney for plaintiff. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. Proc. The PLAINTIFF requests that the DEFENDANT produce the following documents and things in your possession, custody or control in accordance with Rules 26 and 34 of the North Carolina Rules of Civil Procedure for inspection and copy at the offices of Share sensitive information only on official, secure websites. Draft your answers. Access from your Country was disabled by the administrator. Unless otherwise specified, these interrogatories are limited to the time period from January 1, 1995, to and including the date of service of these interrogatories. Sample interrogatories from State Farm in one of Tien Law Firm's personal injury litigation cases, which resulted in a settlement offer from State Farm for our client on the eve of trial. 2. Browse Workers Compensation forms and publications below. Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. But please read the interrogatories carefully and make sure they fit your case. endstream endobj 71 0 obj <> endobj 3 0 obj <> endobj 1 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 5 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 8 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 11 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 14 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 17 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 20 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 23 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 26 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 29 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 32 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 35 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 38 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 41 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 44 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 47 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 50 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 53 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 56 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 59 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 62 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 65 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 68 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 264 0 obj <>stream 0000006248 00000 n Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. Employer Notice of Workers' Compensation Insurance Coverage:this link will take you to the NJ Compensation Rating & Inspection Bureau's website. DEJON WELCOME, CIEMON MOUZON. b. has the purpose or effect of encouraging any dental laboratory or dentist to limit the use of, or refrain from using, the products of any other person. 0000001851 00000 n 0000001288 00000 n The last case I referred to them settled for $1.2 million. Answers to Uniform Interrogatories by Letter of Demand The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun, and vice versa; and the past tense shall include the present tense where the clear meaning is not distorted. More sample discovery List of Sample Objections Sometimes, it is hard to come up with the exact words of why you want to object or to match the feeling that the request is objectionable with the appropriate law. The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. Serve a copy of the response to each party in the litigation. 14-36 (relating to strike). The phrase "describe in detail" as used in these interrogatories includes a request for a complete description and explanation of the facts, circumstances, analysis, opinion and other information relating to (as that phrase is defined below) the subject matter of a specific interrogatory. A person who receives interrogatories has 30 days to respond in writing. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. The State of NJ site may contain optional links, information, services and/or content from other websites operated by third parties that are provided as a convenience, such as Google Translate. 4. The following Interrogatories are served upon you pursuant to Fed. Rule 4:17-4. Where knowledge, information, or documents are requested, such request encompasses knowledge, information or documents in your possession, custody or control, or in the possession, custody or control of your staff, agents, employees, representatives and, unless privileged, attorneys, or any other person who has possession, custody or control of your proprietary knowledge, information or documents. This form must be signed by both the subscriber and the firms Contact Person prior to submitting. hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 Ans. APPELLATE DIVISION. 2013-04-26T13:58:46-05:00 0000003987 00000 n Request for Records Inspection: this form must be completed and signed before the Division can release records. The first questions you'll encounter in interrogatories for a loss of consortium will be similar to the kinds of questions you can expect in any kind of injury case: your full name, address, social security number, and possibly your employment information. A .gov website belongs to an official government organization in the United States. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. Sample Interrogatories for Assault and Battery to Defendant You are here: Plaintiff's Interrogatories - Assault and Battery by a Third Party How to Discover Information to Get Tort Damages from the Person Who Assaulted and Battered You Assault and battery are not only crimes but also intentional torts under civil law. The attorneys at Hanlon Niemann have decades of complex trial experience ready to work for you. Use the saved form as a template for future Adjournment Requests. Defendants and their attorneys tend to use the same standard form interrogatories in all cases so these interrogatory examples should give you a good idea of what to expect. It is trite, but you have to digest each word. 8. 0 Make sure you are not objecting to form interrogatories approved by the court. If a party denies a request for admission that goes to a critical component of Plaintiff's personal injury case, an alternative interrogatory asks the defendant to set forth all facts and evidence upon which the defendant intends to rely upon at trial to support the defense lawyer's denial. Interrogatories are written questions answered under oath. They also object because a particular word is not defined (no matter what the word is, right down to question what the definition of "is" is). Defendants and their attorneys tend to use the same standard form interrogatories in all cases so these interrogatory examples should give you a good idea of what to expect. They are to be answered by you fully, in writing, on oath, and within 30 days of their receipt, unless by agreement or Court order such time is extended: (a) These Interrogatories are continuing in character, so as to require you to file supplemental answers at . We have reports from judges and defense lawyers of lawyers who have cut and pasted example interrogatory questions from our website in their own discovery without even changing all the names and facts. 0000015309 00000 n Related Forms and Guidance . 1: State your full name, current address and any and all other names which you have used or by which you have been known. 0000004058 00000 n (legal size paper), Fondo De Segunda Incapacidad - Guia del Beneficiario, WC Research Manual - link to the instructions page, Report of Non-Compliance (online): submit this form to report an uninsured employer, NJ Benefit Letter - Medical Only:document maintained at the Compensation Rating and Bureau (NJCRIB) website, NJ Benefit Letter - Indemnity:document maintained at the Compensation Rating and Bureau (NJCRIB) website, NJ Benefit Letter Usage Directions:document maintained at the Compensation Rating and Bureau (NJCRIB) website. 4. Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. Toolkit http://www.activepdf.com An official website of the United States government. Another favorite objection is that the plaintiff bears the burden, so no answer is required, an objection that is beyond silly. The second part of this motion is directed at certain interrogatories, 11 in number, served by the plaintiff upon the defendants. NEW JERSEY'S CIVIL COURT PROCEDURES UPDATED AS OF JANUARY 2011 NEW JERSEY INSTITUTE OF CONTINUING LEGAL EDUCATION One Constitution Square, New Brunswick, N.J. 08901-1520 (732) 249-5100 The New Jersey Institute for Continuing Legal Education Celebrating over 40 years of service to the bench and bar 0000040914 00000 n See, R. 4:17-1(a). Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. Order to Show Cause and to Appoint a Law Guardian with Care and Supervision. Allstate GEICO The term "document" includes all drafts of a document and all copies that differ in any respect from the original, including any notation, underlining, marking, or information not on the original. Read them. Except as otherwise provided by R. 4:17-1(b), the number of interrogatories or of sets of interrogatories to be served is not limited except as required to protect the party from annoyance, expense, embarrassment, or oppression. The term "document" also includes electronically stored data from which information can be obtained either directly or by translation through detection devices or readers; any such document is to be produced in a reasonably legible and usable form. 3. Limitation of Interrogatories. Written Questions ("Written Interrogatories") (The court rule about these is CR 33.) DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. No agreement, understanding, or stipulation by the Department of Justice or any of its representatives purporting to modify, limit, or otherwise vary these interrogatories shall be valid or binding on the Department of Justice unless confirmed or acknowledged in writing (or made of record in open court) by a duly authorized representative thereof. Sample Plaintiff's Answers to Defendant's Interrogatories. "Identify" or "identity" means to state or a statement of: a. in the case of a person other than a natural person, its name, the address of its principal place of business (including zipcode), its telephone number, and the name of its chief executive officer, as well as, if it has a person other than a natural person that ultimately controls it, that other person's name, the address of that person's principal place of business (including zipcode), that other person's telephone number, and the name of that other person's chief executive officer; b. in the case of a natural person, his or her name, business address and telephone number, employer, and title or position; c. in the case of a communication, its date, type (e.g., telephone conversation or discussion), the place where it occurred, the identity of the person who made the communication, the identity of the person who received the communication, the identity of each other person when it was made, and the subject matter discussed; d. in the case of a document, the title of the document, the author, the title or position of the author, the addressee, each recipient, the type of document, the subject matter, the date of preparation, and its number of pages; and.