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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. Sample interrogatories to the defendant car owner 1. 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. For any interrogatory or part of an interrogatory which you refuse to answer under a claim of privilege, submit a sworn or certified statement from your counsel or one of your employees in which you identify the nature of the information withheld; specify the grounds of the claimed privilege and the paragraph of these interrogatories to which the information is responsive; and identify each person to whom the information, or any part thereof, has been disclosed. 2. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. Related Forms and Guidance . to schedule a free consultation with our team. Plaintiffs' complaint was dismissed with prejudice for failure to provide complete answers to interrogatories and completely respond to a demand for production of documents by order . Official websites use .gov 11. Interrogatories (NJ) by Practical Law Litigation Maintained New Jersey 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. SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE Amendments may be allowed thereafter only if the party seeking to amend certifies therein that the information requiring the amendment was not reasonably available or discoverable by the exercise of due diligence prior to the discovery end date. 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. In law, interrogatories (also known as requests for further information) [1] are a formal set of written questions propounded by one litigant and required to be answered by an adversary in order to clarify matters of fact and help to determine in advance what facts will be presented at any trial in the case. endobj The next three sample sets are sent throughout the course of discovery. They are just looking for creative ways to circumvent answering discovery. Case Management Order. Figure out how long you have to respond. But you have to make sure the client owns the language. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. Interrogatories not stricken must be answered within the unexpired period of the sixty (60) days that remained when the notice of motion was served, or as the court directs. 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 In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. Pursuant to Fed. Subscriber Application only (fillable): this form needs to be completed if a law firm, insurance carrier or self-insured is interested in adding an additional subscriber to access COURTS on-line and the firm has already established a Contact Person with the Division. 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. "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. 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. first. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. 30 0 obj <> endobj Use these sample interrogatories however you like. 0000003166 00000 n 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. Then draft your discovery and demand answers that fairly and honestly answer the questions. wrP+:y. 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. _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. Hurley v. The Atlantic City Police Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. But the pursuit is worth getting proper and complete answers. 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. Describe in detail and quantify your company's costs or expenses attributable to each dealer to whom you sell prefabricated artificial teeth, separately for each year, and separately for each such dealer, including but not limited to administrative, transactional or other costs or expenses relating to tooth returns or exchanges, drop-shipments, inventory management (including computer hardware or software provided to dealers by Dentsply), training, sales support, marketing, or advertising. R. Civ. hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 Think about the case individually. If you believe your employer decided against promoting you because of a discriminatory reason, you should talk to the attorneys at Swartz Swidler. 0000015309 00000 n 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 0000001427 00000 n If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. It can be either in the form of a question (usually contention interrogatories), or they can direct the answering party to supply accurate information that is described. 2. 1. A Workers' Guide to Workers' Compensation in New Jersey (legal size paper), Guia Interpretativa para el Trabajador A la Ley de Compensacion al Trabajador en Nueva Jersey (legal size paper), Uninsured Employers Fund Pamphlet: provides the regulations associated with the Uninsured Employers Fund (legal size paper), Second Injury Fund - A Beneficiary's Guide: provides necessary information to recipients of second injury fund benefits. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. 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. Call me for a free consultation and help with responding to the requests for information. APPELLATE DIVISION. 0000002216 00000 n previous. Uniform Interrogatories in New Jersey Rule 4 :17-1(b)(2) Cases > > Read More.. (b) residential cases involving six or more single-family homes or housing units. Identify the person signing and attesting to the truthfulness of these Interrogatories, and, if a different individual, the custodian of any business records relating to the premises. 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. Answers to Uniform Interrogatories by Letter of Demand 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. 1. 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. 73 0 obj <> endobj 74 0 obj <> endobj 265 0 obj <>stream Insurance Carrier Contact form (online): this form to designate a contact person must . 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. Many use this objection to the simplest of questions. L-3773-15. The first part of these interrogatories is directed to certain hospital records. 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. This Standard Document has integrated notes with important explanations and drafting tips for the caption, introduction, signature block, definitions, instructions, specific interrogatories, and answering party's form certification. State your full name, your present address, and date of birth. 2. 10. Request for Records Inspection: this form must be completed and signed before the Division can release records. 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. Interrogatories in Nursing Home Negligence Cases. 5. 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). 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. Superior Court of New Jersey, Law Division. They are battle tested and we think they are pretty good. Proc. The interrogatories shall be so arranged that after each separate question shall appear a blank space reasonably calculated to enable the answering party to have the answer typed in. Adobe Acrobat 8.13 Paper Capture Plug-in endobj 0000048970 00000 n The following Interrogatories are served upon you pursuant to Fed. 8. application/pdf : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. 0000015230 00000 n 0000004058 00000 n Most states allow 30 days to respond (twenty-five in federal court under Rule 33). 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. 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 4!mU>]3Nn6~p ,5_Rn]`R.nQirvuA+`i&.8ZfS |cg2'~pY>+8u4>)n9wv|aS9)y>P4}/fd`0W2bUOg"~yf;+[?JZjbtt5qr'r4"|D>fYLZCCE+zX9/+3qyq#1$x,8U1UBV(hSwa3>"n.$2=b. interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. NJ Art of Advocacy - Discovery See Part III: Interrogatories and Requests for Production of Documents. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. Frivolous objections come in many shapes and sizes. 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. The party serving the interrogatories shall furnish the answering party with the original thereof. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. The attorneys at Hanlon Niemann have decades of complex trial experience ready to work for you. 12. <> CERTIFICATE OF SERVICE. 1: State your full name, current address and any and all other names which you have used or by which you have been known. 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. Next, the interrogatories will likely ask . 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. Insurance defense counsel often refuses to answer discovery. R. Civ. Because the number of requests is restricted without a court order or an agreement among the parties, interrogatories in a complex case should be carefully drafted to request only information that a lawyer cannot find using other discovery mechanisms. Bring them in for an appointment to go over the answers. 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. uuid:c389e0db-e0fb-49a3-99ce-ba737d89aee6 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. Sample Plaintiff's Answers to Defendant's Interrogatories. (We do too.) Copyright 1999 2023 GoDaddy Operating Company, LLC. Below is a sample set of interrogatories and requests for production of documents that an injured party (the "plaintiff") might send to the defendant in a slip and fall injury lawsuit. Another tactic that leads to quality information about defendant's case is using alternative interrogatories. 7. State your company's annual unit and dollar sales, separately for each type or line of prefabricated artificial teeth your company sold or manufactured in any country other than the United States, separately for each such country, and separately for 1985 and each subsequent year. You use sample interrogatories because there are some pieces of information you want in every single case. If an interrogatory has five related subparts, it will be counted as five interrogatories. 2013-04-26T13:58:46-05:00 3. I, I, XXX certify that on this 29th day of the month of October, 2009. 2. 0000037811 00000 n 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. Questions About Marriage and Marital History. Decided February 14, 1963. 14-36 (relating to strike). Download Form . Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE 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. $@ (&*,RLo0dNevce1%9%CYD}sTwY,Ps`)2ro O}+%=^g[V9zvhbgq1xpBk +C:@D7D2:L0 'h00X@,ggZ `( 4@xK?Hp4p$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 Except as otherwise provided by R. 4:17-4(e), if a party who has furnished answers to interrogatories thereafter obtains information that renders such answers incomplete or inaccurate, amended answers shall be served not later than 20 days prior to the end of the discovery period, as fixed by the track assignment or subsequent order. IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. Call us today at (856) 685-7420 to schedule a free consultation. Pursuant to Tennessee Rule of Civil Procedure 26.05(2) these interrogatories are continuing in nature requiring supplementation with such additional information to which you will have access in the future. #+wmoSd&Vx7H3"uk]v0 A"`>MB-u6`[dxd;X!CfD3w\BT!g#WQILYgUXTt!2VpPvYpogZzS1(J |J/-T%w5m 1l05Xgh}nH.t`(e@Q:gL^6pVIE)D- {5hMKdzo`-P2d+!Bc~ RTR+[c(GC7N6;4Vl[ Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) If you have any questions about New Jersey contract law and contract litigation, then please contact Fredrick P. Niemann, Esq. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. State whether you purchased the motor vehicle at issue in this litigation (hereinafter referred to as "your vehicle") new or used, and specify: (a) the make, model, and year of your vehicle; You must answer each interrogatory separately and fully in writing under oath, unless you believe there is a legal reason not to answer it (if you object to it). 1. Google Translate is an online service for which the user pays nothing to obtain a purported language translation. -Read Full Disclaimer. 8. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. of the California Rules of Court, these interrogatories must not be used until the asking party has List your occupation or job (full and/or part-time) and employers' name and address during the last five (5) years, starting with your present employer. I also understand that Miller & Zois works with multiple law firms on these claims and that I may be contacted by an affiliated law firm working with Miller & Zois on these lawsuits. 6/2014. Call (804) 251-1620 or (757) 810-5614 today. The form must be signed by the firm's Contact Person prior to submitting. (Update: Yep, that is what happened!). Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Bergen County Law Office. (Caption) 1. Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. Serve a copy of the response to each party in the litigation. In most jurisdictions, parties may serve 30 written questions. You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). 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 8. *266 Mr. David A. Rappeport, attorney for plaintiff.