But please read the interrogatories carefully and make sure they fit your case. For any paragraph that requests information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in any country other than the United States, the information called for includes all information in your possession, custody or control maintained in both the United States or in any other country. 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. <>>> On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. Employer Notice of Workers' Compensation Insurance Coverage:this link will take you to the NJ Compensation Rating & Inspection Bureau's website. 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. 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. "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. Pursuant to Fed. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. x[[o~7+WIA`Ec)4$/]?3CR"%QEcIKsfD6yxnw7|)KOn>$Xsf*Q,-ePY?%7?Ls8ci=`.vJy}B'2El ]X`9O3.QZL}x$c$]QIAK#la7gF`,@RDoWWAuLC'_{qZg.uOV\;NSyd/&ii%x-Y*dH6 .e"U[`lrijlPS(oS.20u,}x7_({po%e5 ;kJ4.r4 cM&^T^g}/2-EC5K4^\x/R!AV%,k|HA cec0&Vx[- }/GW)S!"pD/3_sc7\Z,1rF? 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* Without limitation on the term "control" as used in the preceding paragraph, a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person. Interrogatory No. Call (804) 251-1620 or (757) 810-5614 today. 0000003987 00000 n Serve a copy of the response to each party in the litigation. 1. 3. NJ Art of Advocacy - Discovery See Part III: Interrogatories and Requests for Production of Documents. We have spent a lot of time fine-tuning our interrogatory questions over the years. SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE $@ (&*,RLo0dNevce1%9%CYD}sTwY,Ps`)2ro O}+%=^g[V9zvhbgq1xpBk +C:@D7D2:L0 'h00X@,ggZ `( 4@xK?Hp4p$T`bm20)0 \ endstream endobj 548 0 obj 301 endobj 522 0 obj << /Type /Page /Parent 516 0 R /Resources << /ColorSpace << /CS2 529 0 R /CS3 530 0 R >> /ExtGState << /GS2 538 0 R /GS3 540 0 R >> /Font << /TT4 528 0 R /TT5 523 0 R /TT6 525 0 R /TT7 533 0 R /C2_1 536 0 R >> /ProcSet [ /PDF /Text ] >> /Contents 531 0 R /MediaBox [ 0 0 612 792 ] /CropBox [ 0 0 612 792 ] /Rotate 0 /StructParents 0 >> endobj 523 0 obj << /Type /Font /Subtype /TrueType /FirstChar 32 /LastChar 32 /Widths [ 250 ] /Encoding /WinAnsiEncoding /BaseFont /JOMFEK+Garamond /FontDescriptor 526 0 R >> endobj 524 0 obj << /Type /FontDescriptor /Ascent 1005 /CapHeight 718 /Descent -220 /Flags 32 /FontBBox [ -115 -307 1260 1122 ] /FontName /JOMFLP+CenturyGothic-Bold /ItalicAngle 0 /StemV 136 /FontFile2 546 0 R >> endobj 525 0 obj << /Type /Font /Subtype /TrueType /FirstChar 32 /LastChar 85 /Widths [ 280 0 0 0 0 0 0 0 0 0 0 0 0 0 280 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 740 0 780 700 520 480 840 0 280 0 0 0 0 740 840 0 0 580 520 420 640 ] /Encoding /WinAnsiEncoding /BaseFont /JOMFLP+CenturyGothic-Bold /FontDescriptor 524 0 R >> endobj 526 0 obj << /Type /FontDescriptor /Ascent 861 /CapHeight 0 /Descent -263 /Flags 34 /FontBBox [ -139 -307 1063 986 ] /FontName /JOMFEK+Garamond /ItalicAngle 0 /StemV 0 /FontFile2 537 0 R >> endobj 527 0 obj << /Type /FontDescriptor /Ascent 905 /CapHeight 718 /Descent -211 /Flags 32 /FontBBox [ -665 -325 2028 1037 ] /FontName /JOMEEJ+Arial /ItalicAngle 0 /StemV 94 /XHeight 515 /FontFile2 539 0 R >> endobj 528 0 obj << /Type /Font /Subtype /TrueType /FirstChar 32 /LastChar 167 /Widths [ 278 0 355 0 556 0 0 0 333 333 0 0 278 333 278 278 556 556 556 556 556 556 556 556 556 556 278 278 0 0 0 556 0 667 667 722 722 667 611 778 722 278 500 0 556 0 722 778 667 0 0 667 611 0 0 944 0 667 0 0 0 0 0 0 0 556 556 500 556 556 278 556 556 222 222 500 222 833 556 556 556 556 333 500 278 556 500 722 500 500 500 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 222 333 333 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 556 ] /Encoding /WinAnsiEncoding /BaseFont /JOMEEJ+Arial /FontDescriptor 527 0 R >> endobj 529 0 obj [ /ICCBased 541 0 R ] endobj 530 0 obj /DeviceGray endobj 531 0 obj << /Filter /FlateDecode /Length 532 0 R >> stream 21. 0000000951 00000 n www.fraudstoppers.org/wp-content/uploads/Sample-Interrogatories.pdf, Mozilla/5.0 (iPad; CPU OS 15_5 like Mac OS X) AppleWebKit/605.1.15 (KHTML, like Gecko) GSA/219.0.457350353 Mobile/15E148 Safari/604.1. 7. Identify all agreements or contracts between the plaintiff and defendant 0000015309 00000 n 2. Figure out how long you have to respond. 4:46-2(c) > > Read More.. MOVING PAPERS stream DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE 7. Save the form onto your computer byhitting Save As. Attorneys hate taking positions before trial. But you have to make sure the client owns the language. The first part of these interrogatories is directed to certain hospital records. Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. 19. We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers, Sample Discovery Requests in Personal Injury Lawsuits. Think about the questions that box in the defendant (in one direction or the other). Interrogatories are written sets of questions that both sides of the case can send to one another. Rule 4:17-3. N.J.R. 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. If you are the site owner (or you manage this site), please whitelist your IP or if you think this block is an error please open a support ticket and make sure to include the block details (displayed in the box below), so we can assist you in troubleshooting the issue. Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. State the marginal cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline. 1. If an interrogatory has five related subparts, it will be counted as five interrogatories. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. The objections are, of course, drafted by the attorney. INTERROGATORIES TO PLAINTIFF Ans. Make sure you are not objecting to form interrogatories approved by the court. Form, Service and Time of Answers, Rule 4:17-5. 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. 2. 10. Princeton, New Jersey 08542-0627 Tel. Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. Separately for 1997 and each subsequent year, describe in detail and quantify each separate cost or expense relating to training or educating dealers' personnel, dental laboratories' personnel, and dentists, and to the extent possible, allocate the costs and expenses between dealers, dental laboratories, and dentists. INTERROGATORIES 1. THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. 1: State your full name, current address and any and all other names which you have used or by which you have been known. endstream endobj 31 0 obj <> endobj 32 0 obj <> endobj 33 0 obj <>stream We draft our client's answers to save them the hassle of having to do so and because we want to word the responses in a certain way. In determining the number of questions, you can ask, subparts are counted separately. INTERROGATORIES SAIA MOTOR FREIGHT LINE, LLC Information If you contend that Plaintiff has sued the wrong party or that your name is incorrectly stated in this lawsuit, please explain the basis for your contention and identify the correct legal entity for the correct party in interest to this suit. Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. application/pdf Pursuant to the Rules of Court for the Chancery Division, Family Part, "Interrogatories as to all issues in all family actions may be served by any party as of course" in accordance with Rule 4:17, which applies to Interrogatories for civil practice in New Jersey Courts. They are just looking for creative ways to circumvent answering discovery. 3643, Mark J. Botti William E. Berlin Michael S. Spector Michael D. Farber Health Care Task Force Antitrust Division Washington, D.C. 20004 U.S. Department of Justice 325 7th Street, N.W., Suite 400 Washington, D.C. 20530 (202) 307-0827, Interrogatory Motions, Memoranda, and Orders, This document is available in two formats: this web page (for browsing content) and. DEJON WELCOME, CIEMON MOUZON. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). In a case deemed complex under rule 3.400 et seq. *266 Mr. David A. Rappeport, attorney for plaintiff. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. 1. 0000056111 00000 n Sample Interrogatories for Breach of ContractPlaintiff to Defendant You can find some examples of interrogatories below: Did the defendant execute a written contract with the plaintiff? 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). Draft your answers. FOR PLAINTIFF UNITED STATES OF AMERICA: Carl Schnee UNITED STATES ATTORNEY FOR THE DISTRICT OF DELAWARE, By: _________________________________ Judith M. Kinney Assistant United States Attorney U.S. Attorney's Office 1201 Market Street, Suite 1100 Wilmington, DE 19801 (302) 573-6277 Delaware Bar No. 3. "Shade guide" means any device used to match the color or shade of prefabricated artificial teeth to a patient's natural teeth for the specifications contained in a dentist's prescription for dentures or any other removable or fixed dental prosthetic device. Service, Scope of Interrogatories, Rule 4:17-2. 5. "Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons. Focusing just on this is better than reading a thousand different articles on developing discovery. Follow instructions on the form. 0000015230 00000 n Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. 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. If you have any questions about New Jersey contract law and contract litigation, then please contact Fredrick P. Niemann, Esq. 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. Time to Serve Interrogatories. 2013-04-26T13:58:46-05:00 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. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. 2 0 obj 0000001829 00000 n Frivolous objections come in many shapes and sizes. CN: 10151. previous. Secure .gov websites use HTTPS I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424. As suggested above, you will often get this response even when you using template questions employed by the court. 99-005 (MMS) PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. Employee's Claim Petition(can be used for Amended CP), Employee's Claim Petition Supplemental Page, Application for Review or Modification of Formal Award (can be used for Amended ReOpener), Dependency Claim Petition(can be used for Amended DCP), Dependency Claim Petition To Convert Voluntary Tender to Formal Judgment, Notice of Motion for Temporary and/or Medical Benefits(fillable), Standard petitioner's occupational interrogatory form, Second Injury Fund Verified Petition(fillable), Medical Provider Application for Payment or Reimbursement of Medical Payment, Uninsured Employer's Fund Information Packet, Respondent's Answer to Claim Petition (can be used for Amended Answer), Respondent's Answer to Application for Review & Modification of Formal Award (can be used for Amended Answer), Respondent's Answer to Dependency Claim Petition, Answering Statement for Motion for Medical and/or Temporary Benefits(fillable), Respondent's Answer to Medical Claim Petition, Standard respondent's occupational interrogatory form, Request for Adjournment / Ready Hold - page 1 (fillable). "Document" means any written, recorded, or graphic material of any kind, whether prepared by you or by any other person, that is in your possession, custody, or control. CN: 10159. L-3773-15. State your company's annual unit and dollar sales separately for each type or line of prefabricated artificial teeth that your company sold or manufactured for each year during the relevant time period. Allstate GEICO 0000001288 00000 n 6/2014. Copyright 1999 2023 GoDaddy Operating Company, LLC. Package contains both the Designation of Contact form and Subscriber application form. Search for another form here. Official websites use .gov If you think you need an extension to answer, ask for it early. 5. State your full name, home address, business address, and occupation. But you are making a mistake if you do not craft interrogatories that are specific to your case. Related Forms and Guidance . Use these sample interrogatories however you like. This rule does not direct how the questions are to be asked. 33. 0000002401 00000 n Don't take the insurer's set of written interrogatories lightly. 0000049177 00000 n 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. 0000040696 00000 n Next, the interrogatories will likely ask . 0000001427 00000 n Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. Citing Lehmann v. Toys 'R' Us, 132 N.J. 587, 611 (1993), the New Jersey District Court held that the Plaintiff may use evidence that other women in the workplace were sexually harassed because the plaintiff's work environment is affected not only by conduct directed at herself but also by the treatment of others. Drafting Interrogatories to Support a Fraud Claim by Practical Law Commercial Litigation Maintained USA (National/Federal) A Practice Note explaining the basic considerations for counsel drafting interrogatories to support a common law fraud claim under state law. 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. 8. Your landlord must respond to these requests under oath; they are then admissible in court if you need them. You need to mold them to the facts. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. 1. interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. Just think about what you are trying to prove at trial and explore those issues. In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. All amendments to answers to interrogatories shall be binding on the party submitting them. 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 . A-5298-07T25298-07T2. District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. The case settled and I got a lot more money than I expected. I, I, XXX certify that on this 29th day of the month of October, 2009. Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. They quite literally worked as hard as if not harder than the doctors to save our lives. Except as provided in R. 4:17-1(b)(2), initial interrogatories shall be served by plaintiff as to each defendant within 40 days after service of that defendant's answer and each defendant shall serve initial interrogatories within said 40-day period. Report of Non-Compliance (online): this form may be used by any individual or organization to report allegations of failure on the part of an employer to maintain workers' compensation insurance coverage or obtaining authorization to self-insure. Answer each interrogatory fully. Resource Family Information Form (Word form) CN: 10159. Think about the case individually. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 8. These are "Communication" means any disclosure, transfer, or exchange of information or opinion, however made. Number of Copies Served; Form of Interrogatories. 0000004028 00000 n Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action.
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