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* 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. 2. %PDF-1.3 % DEJON WELCOME, CIEMON MOUZON. 7. Rule 4:17-8. In a case deemed complex under rule 3.400 et seq. I, I, XXX certify that on this 29th day of the month of October, 2009. 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE DOCKET NO. Written interrogatories are a useful discovery tool for plaintiffs in all types of tort cases. Copyright 1999 2023 GoDaddy Operating Company, LLC. Service, Scope of Interrogatories, Rule 4:17-2. A person who receives interrogatories has 30 days to respond in writing. APPELLATE DIVISION. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> (Caption) 1. Think about the hard questions that you would like to get answers to read to a jury. %PDF-1.5 responses to first set of interrogatories ELECTRONICALLY FILED - 2018 Mar 15 2:01 PM - GREENVILLE - COMMON PLEAS - CASE#2014CP2304432. "Exclusive arrangement with a dealer" means any proposed or actual agreement, arrangement, policy, program, practice, term or condition of your company that: a. requires any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person; or. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. Case Management Order. 0000006225 00000 n Use, Filing and Effect of Interrogatories. A true copy of the 10-page Request for Interrogatories was served on The New Superior Court of New Jersey, Chancery Division - Essex Vincinage, at 212 Wasington Street, Eighth Floor, Newark, New Jersey. 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. DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. 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. Make your practice more effective and efficient with Casetexts legal research suite. The case settled and I got a lot more money than I expected. So both the client and the lawyer are usually involved in preparing these written responses. 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. B P Z b G H X ` m n u h7 h. 3. All amendments to answers to interrogatories shall be binding on the party submitting them. HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. 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. "Dealer" means any person that distributes any dental products of any other person or purchases or acquires any such product for the sole purpose of reselling such products to any other person, such as a dental laboratory, dentist, dental school or government entity. In 1994, Maryland Rule 2-421 was amended to allow a party to serve more than a single set of interrogatories. 0000002957 00000 n A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. 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 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. A .gov website belongs to an official government organization in the United States. 20. "Person" means any natural person, corporation, company, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission, office or other business or legal entity, whether private or governmental. 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. Objections to Interrogatories, Rule 4:17-6. The party serving the interrogatories shall furnish the answering party with the original thereof. 519 0 obj << /Linearized 1 /O 522 /H [ 1427 424 ] /L 157345 /E 66972 /N 14 /T 146846 >> endobj xref 519 30 0000000016 00000 n 0000001829 00000 n 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. Bergen County Law Office. Then draft your discovery and demand answers that fairly and honestly answer the questions. 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. %%EOF CN: 10153. 0000003390 00000 n Number of Copies Served; Form of Interrogatories. 0000038018 00000 n A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . 12. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. wrP+:y. 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? The objections are, of course, drafted by the attorney. 8/9/97 1. (b) It is permissible for interrogatories to include a request for a copy of a document. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Unlike oral testimony at a deposition, written statements are much harder to wiggle out of later so interrogatories can be very effective at locking a defendant into a position on key points. 8/22. 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). 3. Hb```f`` 2. 1: State your full name, current address and any and all other names which you have used or by which you have been known. 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. 0000002401 00000 n trailer << /Size 549 /Info 514 0 R /Root 520 0 R /Prev 146835 /ID[] >> startxref 0 %%EOF 520 0 obj << /Type /Catalog /Pages 517 0 R /Metadata 515 0 R /OpenAction [ 522 0 R /XYZ null null null ] /PageMode /UseNone /PageLabels 513 0 R /StructTreeRoot 521 0 R /PieceInfo << /MarkedPDF << /LastModified (D:20020103201212)>> >> /LastModified (D:20020103201212) /MarkInfo << /Marked true /LetterspaceFlags 0 >> >> endobj 521 0 obj << /Type /StructTreeRoot /RoleMap 43 0 R /ClassMap 46 0 R /K 352 0 R /ParentTree 497 0 R /ParentTreeNextKey 14 >> endobj 547 0 obj << /S 335 /L 416 /C 432 /Filter /FlateDecode /Length 548 0 R >> stream Insurance Carrier Contact form (online): this form to designate a contact person must be completed by every insurance carriers and self-insurer authorized to do business in NJ. The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. 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). 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. 0000002216 00000 n Google Translate is an online service for which the user pays nothing to obtain a purported language translation. Another tactic that leads to quality information about defendant's case is using alternative interrogatories. 3.5.2 SP6 (5110) (c) In response to any interrogatory, you are permitted to provide copies of business 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. So asking an interrogatory with several questions does not help keep the number down. The responding party must answer in writing and under oath. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. 0000037811 00000 n 0000049177 00000 n REV. Rule 4:17-3. See, R. 4:17-4(a). Civil Action No. But, either way, get them out quickly. 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. Frivolous objections come in many shapes and sizes. You need to mold them to the facts. *266 Mr. David A. Rappeport, attorney for plaintiff. This is a checklist you might want to consider in providing answers to this discovery: There is one more really important thing to keep in mind. _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. 7. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. L-3773-15. 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. 2013-04-26T13:58:46-05:00 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. %PDF-1.5 % application/pdf 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. 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. at fniemann@hnlawfirm.com or call him toll-free at (855) 376-5291. 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 . hVmO8+t&~wR- ,B3vKSx27GdYJH ) Make sure you are not objecting to form interrogatories approved by the court. State the marginal cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. -Read Full Disclaimer. R. Civ. 1. endobj previous. 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. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo 3. 2. In most jurisdictions, parties may serve 30 written questions. Well-drafted interrogatory answers can put more money in your pocket. (b) residential cases involving six or more single-family homes or housing units. CN: 10160. 14-36 (relating to strike). 0000002626 00000 n 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. 3 0 obj They are just looking for creative ways to circumvent answering discovery. 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. of the California Rules of Court, these interrogatories must not be used until the asking party has SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE % 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. Answer each interrogatory fully. You use sample interrogatories because there are some pieces of information you want in every single case. Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Interrogatories are written questions answered under oath. Read them. Rule 4:17-1. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. 1. Time to Serve Interrogatories. Summary judgment may be granted where the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and the moving party is entitled to summary judgment as a matter of law. 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. Related Forms and Guidance . 2009-03-16T23:32:54Z But you have to make sure the client owns the language. <> R. Civ. Directory of Superior Court Deputy Clerk's Offices/County Lawyer Referral and Legal Services Offices. Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! 18. Answers to Uniform Interrogatories by Letter of Demand 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. hbbd``b` $c`b - V0P2$30RNg The attorneys at Hanlon Niemann have decades of complex trial experience ready to work for you. 4. hJN)OdJBf1GhE wUV4lr1L},rQv'Kwr`qkwFZR&ci1Q We like to draft some of the answers for them based on their responses to our questionnaire and other information we have, and the clients fill in the blanks. Contact the experienced family attorneys at Arons & Solomon Divorce Lawyers today for legal assistance. Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N.W., Room 400 . 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. 0000040696 00000 n 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. Access from your Country was disabled by the administrator. We have a number of samples in all different types of tort cases above. endstream endobj 31 0 obj <> endobj 32 0 obj <> endobj 33 0 obj <>stream The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. 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State: (a) the full name and residence address of each defendant . THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. These are used in conjunction with requests for admission. State your full name, home address, business address, and occupation. {i;6#0O R(VnxTw&:f0L(Y#c{l'tD C]FqC eZ yvm?6=a/DFdrz3 }*S B4,;B@+D\M.F6``CnFwg8#k7"K3T$222LU4iY6@U@pTnb!]1?=g4spG0 `>X=bkKw#>LPb"; 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. 15. endobj Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. Figure out how long you have to respond. 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). 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. 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. "Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons.