sample interrogatories nj

"Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. 14-36 (relating to strike). These are sample written questions that you might receive in your divorce. 0000003987 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. 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. 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. So both the client and the lawyer are usually involved in preparing these written responses. 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. We have a number of samples in all different types of tort cases above. hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 0000001427 00000 n Objections to Interrogatories, Rule 4:17-6. 3. 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! 3. 6. %PDF-1.6 % 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. hJN)OdJBf1GhE wUV4lr1L},rQv'Kwr`qkwFZR&ci1Q 17. Decided February 14, 1963. A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . 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. Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. 1. Washington, DC 20005 . Have ever seen someone running away from their answers to discovery at trial? Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. Sample Interrogatories in Personal Injury and Malpractice Cases. Call (804) 251-1620 or (757) 810-5614 today. Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Written interrogatories are a useful discovery tool for plaintiffs in all types of tort cases. 2. 16. 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. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. 30 0 obj <> endobj interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. Interrogatories in Nursing Home Negligence Cases. Princeton, New Jersey 08542-0627 Tel. > > Read More.. 2013-04-26T13:58:46-05:00 Limitation of Interrogatories. Pursuant to Fed. 19. "Communication" means any disclosure, transfer, or exchange of information or opinion, however made. 1. While the Interrogatories you receive may not be exactly like these, they will be substantially similar. 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. 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. 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 . SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE Adobe Acrobat 8.13 Paper Capture Plug-in hbbd``b` $c`b - V0P2$30RNg 1. 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. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Think about the hard questions that you would like to get answers to read to a jury. It is trite, but you have to digest each word. "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth. But the pursuit is worth getting proper and complete answers. 2009-03-16T23:32:54Z 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. Then draft your discovery and demand answers that fairly and honestly answer the questions. A. All amendments to answers to interrogatories shall be binding on the party submitting them. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action. The party serving the interrogatories shall furnish the answering party with the original thereof. 13. The contact form sends information by non-encrypted email, which is not secure. 0000006979 00000 n 5. -Read Full Disclaimer. Privilege Log. wrP+:y. 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. 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. Ans. 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. Use, Filing and Effect of Interrogatories. Package contains both the Designation of Contact form and Subscriber application form. The last case I referred to them settled for $1.2 million. Directory of Superior Court Deputy Clerk's Offices/County Lawyer Referral and Legal Services Offices. "You," "your" or "your company" means Dentsply. 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). application/pdf Case Management Order. stream Ans. "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. Insurance Carrier Contact form (online): this form to designate a contact person must . 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). 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. See, R. 4:17-4(a). Few plaintiffs' attorneys hold their feet to the fire and make them answer in the face of silly objections. 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. 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. Focusing just on this is better than reading a thousand different articles on developing discovery. 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 first part of these interrogatories is directed to certain hospital records. 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. "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. The following Interrogatories are served upon you pursuant to Fed. NJ Art of Advocacy - Discovery See Part III: Interrogatories and Requests for Production of Documents. 6/2014. Well-drafted interrogatory answers can put more money in your pocket. 0000003390 00000 n Figure out how long you have to respond. 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. first. 0000001829 00000 n If you have any questions about New Jersey contract law and contract litigation, then please contact Fredrick P. Niemann, Esq. Why do they do it? 0000015230 00000 n 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, Washington, D.C. 20530, within 30 days of service of these Interrogatories. 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. The next three sample sets are sent throughout the course of discovery. 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. If you are unable to answer an interrogatory fully, submit as much information as is available, explain why your answer is incomplete, and identify or describe all other sources of more complete or accurate information. 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. Make sure you are not objecting to form interrogatories approved by the court. 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. 5. 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? The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. REV. 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. Think about the questions that box in the defendant (in one direction or the other). Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. 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." (b) Uniform Interrogatories in Certain Actions. Don't take the insurer's set of written interrogatories lightly. 0000004028 00000 n 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 4:17-5(a). HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 <> 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. CN: 10153. The responding party must answer in writing and under oath. Call me for a free consultation and help with responding to the requests for information. 0000006248 00000 n 12. But you have to make sure the client owns the language. Figure out which questions are objectionable. 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. 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. 2. (b) residential cases involving six or more single-family homes or housing units. 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; Your landlord must respond to these requests under oath; they are then admissible in court if you need them. 8/22. Search for another form here. 14. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). 1 0 obj Get help from an experienced discrimination lawyer. 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. endstream endobj startxref 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 %PDF-1.3 % They quite literally worked as hard as if not harder than the doctors to save our lives. 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. Use these sample interrogatories however you like. Art of Advocacy: Preparation of the Case 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. Civil Action No. If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. These questions are referred to as "Interrogatories". 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. Attorneys hate taking positions before trial. 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. Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. 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. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. But if the question is overly broad, vague, privileged, or not relevant, you should object. The case settled and I got a lot more money than I expected. interrogatories, please note: (a) You are required to furnish all information available to you, your agents, employees and attorneys. As a result, we make a lot of diving impossible catches but miss too many fly balls. 0000003166 00000 n Request for Records Inspection: this form must be completed and signed before the Division can release records. Call us today at (856) 685-7420 to schedule a free consultation. It is not a pretty sight. R. Civ. 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. 20. 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. Superior Court of New Jersey, Law Division. The second part of this motion is directed at certain interrogatories, 11 in number, served by the plaintiff upon the defendants. CERTIFICATE OF SERVICE. 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). Hb```f`` 8. Contact the experienced family attorneys at Arons & Solomon Divorce Lawyers today for legal assistance. Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-016-7534, https://content.next.westlaw.com/practical-law/document/Ib7c96852c00111e8a5b3e3d9e23d7429/Interrogatories-NJ?viewType=FullText&transitionType=Default&contextData=(sc.Default). Separately for 1990 and each subsequent year through 1996, describe in detail and quantify each separate cost or expense, and all fees and other income Dentsply collected from third parties, relating to training or educating dentists. "Including" means including, but not limited to. "Relevant time period" means the time period stated in paragraph 1 of the Instructions. We get so much advice as to what we should do. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. N.J.R. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. 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.

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