Interrogatories are written sets of questions that both sides of the case can send to one another. These are used in conjunction with requests for admission. 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. The second part of this motion is directed at certain interrogatories, 11 in number, served by the plaintiff upon the defendants. They are battle tested and we think they are pretty good. *266 Mr. David A. Rappeport, attorney for plaintiff. 0000006979 00000 n
"Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons. 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. As suggested above, you will often get this response even when you using template questions employed by the court. The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. endstream
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In determining the number of questions, you can ask, subparts are counted separately. 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. When practicing family law here in New Jersey, one of the most fact sensitive areas for an attorney to handle is a child custody case.
A person who receives interrogatories has 30 days to respond in writing. Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. 0000003390 00000 n
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. Proc. More sample discovery List of Sample Objections Sometimes, it is hard to come up with the exact words of why you want to object or to match the feeling that the request is objectionable with the appropriate law. 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). But, either way, get them out quickly. This rule does not direct how the questions are to be asked. "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. 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. IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. Think about the case individually. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 14-36 (relating to strike). 1. 8. 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? "Year" means calendar year or the twelve-month period on which your business records are based; if the latter is used in responding to a interrogatory, specify the twelve month period used. Pursuant to Fed. Many use this objection to the simplest of questions. Focusing just on this is better than reading a thousand different articles on developing discovery. 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. "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth. 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. 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. 0000037811 00000 n
A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Case Management Order. 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. 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. The contact form sends information by non-encrypted email, which is not secure. So both the client and the lawyer are usually involved in preparing these written responses. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. Civil Action No. Ans. 30 0 obj
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CN: 10159. 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* 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 TO PLAINTIFF Ans. first. 18. 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. $Kw<8uCyjd2 ]dg`w+Vf};|"8UkT3)yn d"W2=B4oUcFW5L1}!Afm$_nhX!QxnS5Q~h+^ua]3:*. 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 Why do they do it? {i;6#0O R(VnxTw&:f0L(Y#c{l'tD C]FqC
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`>X=bkKw#>LPb"; The case settled and I got a lot more money than I expected. Secure .gov websites use HTTPS A-5298-07T25298-07T2. 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. 0000001851 00000 n
Answer each interrogatory fully. State your full name, home address, business address, and occupation. "Relevant time period" means the time period stated in paragraph 1 of the Instructions. 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). application/pdf Use, Filing and Effect of Interrogatories. 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. endstream
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Pursuant to Fed. The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. 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. 0
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). "Dentsply" means Dentsply International, Inc., each of its predecessors (including Gendex Corporation), successors, divisions, subsidiaries, and affiliates, located both in the United States and in any other country, each other person directly or indirectly, wholly or in part, owned or controlled by it, and each joint venture to which any of them is a party, and all present and former directors, officers, employees, agents, consultants, or other persons acting for or on behalf of any of them. Then draft your discovery and demand answers that fairly and honestly answer the questions. 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. These are 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE Rule 4:17-4. 6/2014. 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). Sample interrogatories to the defendant car owner 1. 15. They are just looking for creative ways to circumvent answering discovery. Princeton, New Jersey 08542-0627 Tel. 0000048970 00000 n
Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. ) FIRST SET OF INTERROGATORIES _____, ) TO DEFENDANT Defendant. ) 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. stream
Download Sample Answer To Interrogatories New Jersey: FileName Speed Downloads Sample Answer To Interrogatories New Jersey [Most popular] 5288 kb/s 1996 Sample Answer To Interrogatories New Jersey | NEW 4174 kb/s 4237 Sample Answer To Interrogatories New Jersey | checked 3591 kb/s 7820 Sample Answer To Interrogatories New Jersey 5834 kb/s 7593 A certification of the amendments shall be furnished promptly to any other party so requesting. wrP+:y. 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. State your full name, your present address, and date of birth. In a case deemed complex under rule 3.400 et seq. (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. 2. 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. The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. 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 . 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. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. 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. 4:46-2(c) > > Read More.. MOVING PAPERS %PDF-1.3
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5. 4. Fortunately, we were sure that the judge that hears the motion to compel has read these rules. "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. The next three sample sets are sent throughout the course of discovery. 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. Just think about what you are trying to prove at trial and explore those issues. A .gov website belongs to an official government organization in the United States. 55 0 obj
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You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court. Hb```f`` 22. If a party denies a request for admission that goes to a critical component of Plaintiff's personal injury case, an alternative interrogatory asks the defendant to set forth all facts and evidence upon which the defendant intends to rely upon at trial to support the defense lawyer's denial. 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. DOCKET NO. Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. State: (a) the full name and residence address of each defendant . 3. hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30
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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. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. CN: 10160. Art of Advocacy: Preparation of the Case The interrogatories may include a request, at the propounder's expense, for a copy of any paper. Toolkit http://www.activepdf.com 8. 4:17-5(a). %PDF-1.5
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19. (b) residential cases involving six or more single-family homes or housing units. Ans. endobj
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. Adobe Acrobat 8.13 Paper Capture Plug-in I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424. "You," "your" or "your company" means Dentsply. 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. 8. Think about the questions that box in the defendant (in one direction or the other). Bergen County Law Office. COURTS on-line Internet Access Application(fillable): this application package needs to be completed if a law firm, insurance carrier or self-insured is interested in accessing COURTS on-line, the Division'son-line case management website. 0000001288 00000 n
THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. Answers to Uniform Interrogatories by Letter of Demand 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. We have a number of samples in all different types of tort cases above. Serve a copy of the response to each party in the litigation. 4. 8/22. While the Interrogatories you receive may not be exactly like these, they will be substantially similar. 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. 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). (Update: Yep, that is what happened!). Interrogatories in Nursing Home Negligence Cases.