They are battle tested and we think they are pretty good. Pursuant to Fed. 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. 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. 0000002401 00000 n 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. In determining the number of questions, you can ask, subparts are counted separately. Time to Serve Interrogatories. Art of Advocacy: Preparation of the Case On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. 7. We have spent a lot of time fine-tuning our interrogatory questions over the years. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. 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. 21. 5. %PDF-1.3 % 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. Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. As suggested above, you will often get this response even when you using template questions employed by the court. 4. 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). 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 1: State your full name, current address and any and all other names which you have used or by which you have been known. In most jurisdictions, parties may serve 30 written questions. The process adds layers of time, expense and tedious effort because a motion must be drafted and typically the judge will require the lawyers to attend a hearing on the motion. Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. stream But the pursuit is worth getting proper and complete answers. Package contains both the Designation of Contact form and Subscriber application form. Objections to Interrogatories, Rule 4:17-6. 5. 0000007135 00000 n 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? It is not a pretty sight. THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. Case Management Order. 16. 2013-04-26T13:58:46-05:00 DEJON WELCOME, CIEMON MOUZON. The first part of these interrogatories is directed to certain hospital records. Proc. A certification of the amendments shall be furnished promptly to any other party so requesting. Just think about what you are trying to prove at trial and explore those issues. 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. 0000037811 00000 n Identify all agreements or contracts between the plaintiff and defendant 55 0 obj <>stream Without limitation on the term "control" as used in the preceding paragraph, a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person. Read them. 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." 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. 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. 0 2. Follow instructions on the form. "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. to schedule a free consultation with our team. DOCKET NO. These are sample written questions that you might receive in your divorce. In 1994, Maryland Rule 2-421 was amended to allow a party to serve more than a single set of interrogatories. Call (804) 251-1620 or (757) 810-5614 today. "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth. In a case deemed complex under rule 3.400 et seq. Decided February 14, 1963. Service, Scope of Interrogatories (a) Generally. 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. 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. State: (a) the full name and residence address of each defendant . 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. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Contact the experienced family attorneys at Arons & Solomon Divorce Lawyers today for legal assistance. Comments and Help with example of sample interrogatories divorce CIVIL CONVICTION STATUS The following persons: (1) Have been convicted of any felony and, at the time of making the application, did not have a "strike" pursuant to G.S. 0000003390 00000 n 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 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. But please read the interrogatories carefully and make sure they fit your case. Defense counsel in a case recently refused to answer discovery because the defendant thought three sets of requests for admission and interrogatories were just too much. Pursuant to the Rules of Court for the Chancery Division, Family Part, "Interrogatories as to all issues in all family actions may be served by any party as of course" in accordance with Rule 4:17, which applies to Interrogatories for civil practice in New Jersey Courts. 0000006248 00000 n Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. Part VII offers additional Model Discovery. 2013-04-26T13:58:46-05:00 Another favorite objection is that the plaintiff bears the burden, so no answer is required, an objection that is beyond silly. Another tactic that leads to quality information about defendant's case is using alternative interrogatories. 1. 0000001288 00000 n They are just looking for creative ways to circumvent answering discovery. A .gov website belongs to an official government organization in the United States. It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline. 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. 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. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. 2. N.J.R. 1. A-5298-07T25298-07T2. If you believe your employer decided against promoting you because of a discriminatory reason, you should talk to the attorneys at Swartz Swidler. %%EOF If an interrogatory has five related subparts, it will be counted as five interrogatories. See, R. 4:17-1(a). 0000003987 00000 n %PDF-1.5 % 8/9/97 1. 0000002957 00000 n But the total number of requests cannot exceed thirty. 7. 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. This rule does not direct how the questions are to be asked. Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. at fniemann@hnlawfirm.com or call him toll-free at (855) 376-5291. So if you can pin down what the arguments will be, you will be in a much better position to structure your case effectively. $@ (&*,RLo0dNevce1%9%CYD}sTwY,Ps`)2ro O}+%=^g[V9zvhbgq1xpBk +C:@D7D2:L0 'h00X@,ggZ `( 4@xK?Hp4p$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 30 0 obj <> endobj 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. Google Translate is an online service for which the user pays nothing to obtain a purported language translation. 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. 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. 0000001427 00000 n Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. 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. If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. "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.