Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). 9. "Relating to" means containing, constituting, considering, comprising, concerning, discussing, regarding, describing, reflecting, studying, commenting or reporting on, mentioning, analyzing, or referring, alluding, or pertaining to, in whole or in part. 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. 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). 0000003987 00000 n Rule 4:17-8. Toolkit http://www.activepdf.com So both the client and the lawyer are usually involved in preparing these written responses. 5. Hurley v. The Atlantic City Police Part IV - Rules Governing Civil Practice in the Superior Court, Tax Court and Surrogate's Courts, Rule 4:16 - Use of Depositions; Objections; Effect; Errors and Irregularities, Rule 4:18 - Discovery and Inspection of Documents and Property; Copies of Documents. b. has the purpose or effect of encouraging any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person. (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. Limitation of Interrogatories. A certification of the amendments shall be furnished promptly to any other party so requesting. 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. 0000004028 00000 n 3. Hb```f`` "Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons. Ans. 8. Civil Action No. 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. 15. 20. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 0000006438 00000 n 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. These questions are referred to as "Interrogatories". Time to Serve Interrogatories. responses to first set of interrogatories ELECTRONICALLY FILED - 2018 Mar 15 2:01 PM - GREENVILLE - COMMON PLEAS - CASE#2014CP2304432. of the California Rules of Court, these interrogatories must not be used until the asking party has Think about the questions that box in the defendant (in one direction or the other). %PDF-1.5 7. 8/9/97 1. 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. and Towson; Carroll County including Westminster; Frederick County including Frederick; Harford County including Abingdon, Bel Air, Belcamp, and Forest Hill; Montgomery County including Germantown and Rockville; Howard County including Ellicott City and Columbia, Washington, D.C. and Washington County including Hagerstown. Interrogatories are written sets of questions that both sides of the case can send to one another. 0000015309 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. interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. 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. 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 You need to mold them to the facts. 0000006685 00000 n Service, Scope of Interrogatories, Rule 4:17-2. 0000006225 00000 n They quite literally worked as hard as if not harder than the doctors to save our lives. N.J.R. 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. It is trite, but you have to digest each word. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court. Washington, DC 20005 . 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. Attorney Calendar E-mail Program application(fillable): this form initiates the transmission of "Attorney Calendar" scheduling notices via e-mail to designated e-mail address(es). 0000000951 00000 n The case settled and I got a lot more money than I expected. 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. Form, Service and Time of Answers, Rule 4:17-5. Pursuant to Fed. 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. The last case I referred to them settled for $1.2 million. State your full name, your present address, and date of birth. 19. #+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[ 3. Think about the hard questions that you would like to get answers to read to a jury. Package contains both the Designation of Contact form and Subscriber application form. In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. I, I, XXX certify that on this 29th day of the month of October, 2009. District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. See, R. 4:17-1(a). Sample Plaintiff's Answers to Defendant's Interrogatories. Contact the experienced family attorneys at Arons & Solomon Divorce Lawyers today for legal assistance. Adobe Acrobat 8.13 Paper Capture Plug-in 34:15-20, Decision of Dismissal (Second Injury Fund), Order for Total Disability with SS Offset (fillable), Order for Total Disability with SIF(fillable), Addendum to Order for Total Disability(fillable), ELECTRONIC CALENDARS, COURTS ON-LINE AND ELECTRONIC FILING FORMS. 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. Don't take the insurer's set of written interrogatories lightly. 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* The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. Directory of Superior Court Deputy Clerk's Offices/County Lawyer Referral and Legal Services Offices. 2. Focusing just on this is better than reading a thousand different articles on developing discovery. 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 Secure .gov websites use HTTPS Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. Make your practice more effective and efficient with Casetexts legal research suite. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. This rule does not direct how the questions are to be asked. 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. Separately for 1997 and each subsequent year, describe in detail and quantify all fees and other income Dentsply collected from third parties relating to training or educating dealers' personnel', dental laboratories' personnel, and dentists, and to the extent possible, allocate the fees and other income between dealers, dental laboratories, and dentists. 1. REV. The attorneys at Hanlon Niemann have decades of complex trial experience ready to work for you. 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. 16. Search for another form here. 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. 8/22. 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. Download Form . Serve a copy of the response to each party in the litigation. $@ (&*,RLo0dNevce1%9%CYD}sTwY,Ps`)2ro O}+%=^g[V9zvhbgq1xpBk +C:@D7D2:L0 'h00X@,ggZ `( 4@xK?Hp4p$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 Interrogatories are written questions answered under oath. 3. . Written responses from a defendant can help narrow down the issues in a case. > > Read More.. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> 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. Don't object just because you don't want to answer the question and try to keep the objection as narrow as possible. But if the question is overly broad, vague, privileged, or not relevant, you should object. B P Z b G H X ` m n u h7 h. Insurance Carrier / Self-Insurer Contact Listing: these individuals can be contacted by judicial staff and attorneys where there has been no appearance or formal response made by the carrier or their counsel on pending Motions for Medical and Temporary Benefits. 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). New Jersey Divorce - Discovery - Interrogatories State: New Jersey Change state Control #: NJ-021B-D Instant Download Buy now Available formats: Word | Rich Text Free Preview Description Related Forms How to Guide All forms provided by US Legal Forms, the nations leading legal forms publisher. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. 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. 1. 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. INTERROGATORIES TO PLAINTIFF Ans. 11. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. Access from your Country was disabled by the administrator. 0000002401 00000 n DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. N.J.R. $Kw<8uCyjd2 ]dg`w+Vf};|"8UkT3)yn d"W2=B4oUcFW5L1}!Afm$_nhX!QxnS5Q~h+^ua]3:*. If an interrogatory has five related subparts, it will be counted as five interrogatories. "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. The following Interrogatories are served upon you pursuant to Fed. All amendments to answers to interrogatories shall be binding on the party submitting them. Princeton, New Jersey 08542-0627 Tel. Use these sample interrogatories however you like. hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 But please read the interrogatories carefully and make sure they fit your case. If you think you need an extension to answer, ask for it early. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. You use sample interrogatories because there are some pieces of information you want in every single case. 8. (We do too.) %PDF-1.5 % "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. Please read through these Interrogatories and prepare your responses, this will save you time 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. 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 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. 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. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth. Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. 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. If you have any questions about New Jersey contract law and contract litigation, then please contact Fredrick P. Niemann, Esq. 2. The term includes agreements; contracts; letters; telegrams; inter-office communications; memoranda; reports; records; instructions; specifications; notes; notebooks; scrapbooks; diaries; plans; drawings; sketches; blueprints; diagrams; photographs; photocopies; charts; graphs; descriptions; drafts, whether or not they resulted in a final document; minutes of meetings, conferences, and telephone or other conversations or communications; invoices; purchase orders; bills of lading; recordings; published or unpublished speeches or articles; publications; transcripts of telephone conversations; phone mail; electronic-mail; ledgers; financial statements; microfilm; microfiche; tape or disc recordings; and computer print-outs. 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. We get so much advice as to what we should do. IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. 14. I understand that submitting this form does not create an attorney-client relationship. CN: 10160. 0000003390 00000 n "Prefabricated artificial teeth" or "teeth" means any prefabricated (as opposed to dental laboratory or dentist constructed) product used in a denture or as an implant to replace one or more natural teeth. SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE NJ Art of Advocacy - Discovery See Part III: Interrogatories and Requests for Production of Documents. 6. 4. Have ever seen someone running away from their answers to discovery at trial? The objections are, of course, drafted by the attorney. 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. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. 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. INTERROGATORIES 1. 0000040696 00000 n Decided February 14, 1963. Public Sector Contact Listing: similar to above listing, A Workers' Guide to Workers' Compensation in New Jersey, Guia Interpretativa para el Trabajador A la Ley de Compensacion al Trabajador en Nueva Jersey, Second Injury Fund - A Beneficiary's Guide, Employer Notice of Workers' Compensation Insurance Coverage, Application for Review or Modification of Formal Award, Notice of Motion for Temporary and/or Medical Benefits, Respondent's Answer to Application for Review & Modification of Formal Award, Answering Statement for Motion for Medical and/or Temporary Benefits, Request for Adjournment / Ready Hold - page 1, Second Injury Fund Information Review Sheet, Order Approving Settlement under NJSA 34:15-20, Order for Distribution of Temporary Award, Order for Total Disability with SS Offset, Attorney Calendar E-mail Program application, COURTS on-line Internet Access Application, Insurance Carrier / Self-Insurer Contact Listing, Governor Phil Murphy Lt. Bring them in for an appointment to go over the answers. 1. An official website of the United States government. 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. 0000006979 00000 n 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.