sample interrogatories nj

4:17-5(a). Answer each interrogatory fully. NJ Art of Advocacy - Discovery See Part III: Interrogatories and Requests for Production of Documents. But the total number of requests cannot exceed thirty. 55 0 obj <>stream The purpose of providing these to our colleagues is that we should all be trying to spend more time maximizing the value of our cases and less time reinventing the wheel. 39 0 obj <>/Filter/FlateDecode/ID[<3DE8017F54D98D5939ED3FFC60811FA0><341CF33D3F5EAB49B7E5710A1889DF18>]/Index[30 26]/Info 29 0 R/Length 62/Prev 47862/Root 31 0 R/Size 56/Type/XRef/W[1 2 1]>>stream Use, Filing and Effect of Interrogatories. (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. Search for another form here. 2. Sample Interrogatories in Personal Injury and Malpractice Cases. IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. Service, Scope of Interrogatories (a) Generally. "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. Get help from an experienced discrimination lawyer. The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. We have a number of samples in all different types of tort cases above. On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. Download Form . 73 0 obj <> endobj 74 0 obj <> endobj 265 0 obj <>stream Ans. "You," "your" or "your company" means Dentsply. 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. Most states allow 30 days to respond (twenty-five in federal court under Rule 33). If you think you need an extension to answer, ask for it early. 3. 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. "Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons. But, either way, get them out quickly. It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline. "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. In determining the number of questions, you can ask, subparts are counted separately. 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. State the marginal cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 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. "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. 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. Pursuant to Fed. Think about the questions that box in the defendant (in one direction or the other). Don't object just because you don't want to answer the question and try to keep the objection as narrow as possible. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. N.J.R. 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. I am so grateful that I was lucky to pick Miller & Zois. Art of Advocacy: Preparation of the Case For any paragraph that requests information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in any country other than the United States, the information called for includes all information in your possession, custody or control maintained in both the United States or in any other country. The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. of the California Rules of Court, these interrogatories must not be used until the asking party has The term "document" includes all drafts of a document and all copies that differ in any respect from the original, including any notation, underlining, marking, or information not on the original. 11. 0000037811 00000 n 4 0 obj Official websites use .gov 0000006685 00000 n The following Interrogatories are served upon you pursuant to Fed. 5. Interrogatories in Nursing Home Negligence Cases. A-4540-16T4 JI SUNG KIM, Plaintiff-Appellant, v. PAUL P. KOBLISKA, Defendant-Respondent. 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. "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth. 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. 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. 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. 1. %PDF-1.5 8/22. 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. State: (a) the full name and residence address of each defendant . Write in plain English and keep in mind that these responses can be read to a jury. CN: 10151. District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. The 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. %PDF-1.5 % As a result, we make a lot of diving impossible catches but miss too many fly balls. 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. "Shade guide" means any device used to match the color or shade of prefabricated artificial teeth to a patient's natural teeth for the specifications contained in a dentist's prescription for dentures or any other removable or fixed dental prosthetic device. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). Focusing just on this is better than reading a thousand different articles on developing discovery. 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. Another tactic that leads to quality information about defendant's case is using alternative interrogatories. Answers to Uniform Interrogatories by Letter of Demand "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. Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. Attorneys hate taking positions before trial. 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? We get so much advice as to what we should do. I understand that submitting this form does not create an attorney-client relationship. 7. wrP+:y. 8. 0000002216 00000 n 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE 9. (Caption) 1. Allstate GEICO first. 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. 3 0 obj 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. Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action. 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. application/pdf 0000003166 00000 n 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. 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. A certification of the amendments shall be furnished promptly to any other party so requesting. 3.5.2 SP6 (5110) 0000040914 00000 n It is trite, but you have to digest each word. 0000001829 00000 n 0000006248 00000 n 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. {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"; Fortunately, we were sure that the judge that hears the motion to compel has read these rules. 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. 1. Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. 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. THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. 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. 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. DEJON WELCOME, CIEMON MOUZON. 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. Make sure you are not objecting to form interrogatories approved by the court. 15. 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. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 0000015309 00000 n uuid:c389e0db-e0fb-49a3-99ce-ba737d89aee6 (fillable), Order Approving Settlement under NJSA 34:15-20:(fillable) (page 1 and 2), Order for Distribution (for child support), Order for Distribution of Temporary Award (for child support), Affidavit of Dependent in Support of Settlement Under N.J.S.A. The form must be signed by the firm's Contact Person prior to submitting. Ans. The next three sample sets are sent throughout the course of discovery. So asking an interrogatory with several questions does not help keep the number down. A. #+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[ Copyright 1999 2023 GoDaddy Operating Company, LLC. 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. N.J.R. State your full name, your present address, and date of birth. You need to mold them to the facts. 0000048970 00000 n Package contains both the Designation of Contact form and Subscriber application form. In 1994, Maryland Rule 2-421 was amended to allow a party to serve more than a single set of interrogatories. 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. 0000001851 00000 n 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 . previous. Pursuant to Fed. 10. R. Civ. Employer Notice of Workers' Compensation Insurance Coverage:this link will take you to the NJ Compensation Rating & Inspection Bureau's website. But you are making a mistake if you do not craft interrogatories that are specific to your case. hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 1. Pursuant to Tennessee Rule of Civil Procedure 26.02(5), if any In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. 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. Adobe Acrobat 8.13 Paper Capture Plug-in Use these sample interrogatories however you like. %%EOF PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. Request for Records Inspection: this form must be completed and signed before the Division can release records. (We do too.) 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). (b) Uniform Interrogatories in Certain Actions. All rights reserved. This rule does not direct how the questions are to be asked. Sample Plaintiff's Answers to Defendant's Interrogatories. 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). Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. You use sample interrogatories because there are some pieces of information you want in every single case. Call us today at (856) 685-7420 to schedule a free consultation. endobj Call (804) 251-1620 or (757) 810-5614 today. 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. 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. Fillable PDF 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. 7. Pursuant to Fed. <>>> 1 0 obj Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. %PDF-1.6 % A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . In a case deemed complex under rule 3.400 et seq. Hb```f``