0000000951 00000 n Have ever seen someone running away from their answers to discovery at trial? See, R. 4:17-4(a). The objections are, of course, drafted by the attorney. 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 R. Civ. "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. 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 Sample interrogatories to the defendant car owner 1. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. endobj You use sample interrogatories because there are some pieces of information you want in every single case. A-5298-07T25298-07T2. %%EOF Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. Your landlord must respond to these requests under oath; they are then admissible in court if you need them. 4:17-5(a). 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. As suggested above, you will often get this response even when you using template questions employed by the court. 0000003390 00000 n 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. A. Copyright 1999 2023 GoDaddy Operating Company, LLC. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. "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. 4. 2. 1. Objections to Interrogatories, Rule 4:17-6. Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) 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 . CN: 10153. 14. 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. All amendments to answers to interrogatories shall be binding on the party submitting them. No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. Write in plain English and keep in mind that these responses can be read to a jury. 0000004058 00000 n Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. Call (804) 251-1620 or (757) 810-5614 today. But if the question is overly broad, vague, privileged, or not relevant, you should object. 2. 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. 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. Hb```f`` 1: State your full name, current address and any and all other names which you have used or by which you have been known. 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. 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. 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. "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. Service, Scope of Interrogatories, Rule 4:17-2. 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. Pursuant to Fed. It is trite, but you have to digest each word. Save the form onto your computer byhitting Save As. While the Interrogatories you receive may not be exactly like these, they will be substantially similar. 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. "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. INTERROGATORIES 1. Sample Interrogatories in Personal Injury and Malpractice Cases. State your full name, home address, business address, and occupation. 7. "Identify" or "identity" means to state or a statement of: a. in the case of a person other than a natural person, its name, the address of its principal place of business (including zipcode), its telephone number, and the name of its chief executive officer, as well as, if it has a person other than a natural person that ultimately controls it, that other person's name, the address of that person's principal place of business (including zipcode), that other person's telephone number, and the name of that other person's chief executive officer; b. in the case of a natural person, his or her name, business address and telephone number, employer, and title or position; c. in the case of a communication, its date, type (e.g., telephone conversation or discussion), the place where it occurred, the identity of the person who made the communication, the identity of the person who received the communication, the identity of each other person when it was made, and the subject matter discussed; d. in the case of a document, the title of the document, the author, the title or position of the author, the addressee, each recipient, the type of document, the subject matter, the date of preparation, and its number of pages; and. 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. 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. These are used in conjunction with requests for admission. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo Governor Sheila Oliver, Department of Labor and Workforce Development, Reporting work accidents and occupational exposures, Supplemental benefits for public safety workers, 2023 Schedule of Disabilities (updated 1/27/23), Insurance Carrier/ Self-Insurer Contact Listing (updated 8/22), Public Sector Contact Listing (updated 8/22), Report of Compensation Paid (updated 7/22), A Workers' Guide to Workers' Compensation in New Jersey (updated 6/22), Insurance Carrier Contact form (updated 4/22), Hearing Cycle Calendar (updated 3/28/2022), Quarterly Surcharge Return (updated 2/22). Another tactic that leads to quality information about defendant's case is using alternative interrogatories. Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Decided February 14, 1963. hbbd``b` $c`b - V0P2$30RNg Identify all agreements or contracts between the plaintiff and defendant 0000004028 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 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. > > Read More.. 13. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. Allstate GEICO I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424. Written interrogatories are a useful discovery tool for plaintiffs in all types of tort cases. The party serving the interrogatories shall furnish the answering party with the original thereof. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 6. 8/22. Why do they do it? 6. 99-005 (MMS) PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. 0000006438 00000 n REV. 19. 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. 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. 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. stream First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. Don't take the insurer's set of written interrogatories lightly. Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 This rule does not direct how the questions are to be asked. (We do too.) For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. Fillable PDF 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. N.J.R. 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. So both the client and the lawyer are usually involved in preparing these written responses. R. Civ. 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* 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. 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." 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). 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. Insurance defense counsel often refuses to answer discovery. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. In most jurisdictions, parties may serve 30 written questions. The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. hagrid's brother name, churchfields wainhomes, recliner armrest covers,
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