Sample interrogatories to the defendant car owner 1. Questions About Marriage and Marital History. endobj 22. 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. 4. hJN)OdJBf1GhE wUV4lr1L},rQv'Kwr`qkwFZR&ci1Q Pursuant to Tennessee Rule of Civil Procedure 26.02(5), if any First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. 0000015309 00000 n 0000038018 00000 n Package contains both the Designation of Contact form and Subscriber application form. 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 biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. It is trite, but you have to digest each word. endstream endobj startxref 10. Think about the case individually. 0000048970 00000 n DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. Have ever seen someone running away from their answers to discovery at trial? Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Use [ edit] Bring them in for an appointment to go over the answers. B P Z b G H X ` m n u h7 h. Call me for a free consultation and help with responding to the requests for information. 0000056111 00000 n previous. Secure .gov websites use HTTPS Access from your Country was disabled by the administrator. 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). Next, the interrogatories will likely ask . Rule 4:17-8. 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. In most jurisdictions, parties may serve 30 written questions. 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). 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. 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. Identify the person signing and attesting to the truthfulness of these Interrogatories, and, if a different individual, the custodian of any business records relating to the premises. 0000015230 00000 n 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. They are just looking for creative ways to circumvent answering discovery. 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. 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. "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. Number of Copies Served; Form of Interrogatories. HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 0000049177 00000 n 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. Service, Scope of Interrogatories, Rule 4:17-2. Make sure you are not objecting to form interrogatories approved by the court. Toolkit http://www.activepdf.com Sample Plaintiff's Answers to Defendant's Interrogatories. 55 0 obj <>stream 0000040696 00000 n 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. We have a number of samples in all different types of tort cases above. Sample interrogatories from State Farm in one of Tien Law Firm's personal injury litigation cases, which resulted in a settlement offer from State Farm for our client on the eve of trial. Call us today at (856) 685-7420 to schedule a free consultation. Sample Interrogatories in Personal Injury and Malpractice Cases. 3.5.2 SP6 (5110) "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. Frivolous objections come in many shapes and sizes. 73 0 obj <> endobj 74 0 obj <> endobj 265 0 obj <>stream You use sample interrogatories because there are some pieces of information you want in every single case. "Document" means any written, recorded, or graphic material of any kind, whether prepared by you or by any other person, that is in your possession, custody, or control. 14-36 (relating to strike). No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. Interrogatories in Nursing Home Negligence Cases. See, R. 4:17-4(a). 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. 4:46-2(c) > > Read More.. MOVING PAPERS The list below contains the sample NJ divorce documents discussed above. These questions are referred to as "Interrogatories". 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. If an interrogatory has five related subparts, it will be counted as five interrogatories. $@ (&*,RLo0dNevce1%9%CYD}sTwY,Ps`)2ro O}+%=^g[V9zvhbgq1xpBk +C:@D7D2:L0 'h00X@,ggZ `( 4@xK?Hp4p$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 0000037811 00000 n 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; 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. 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). All amendments to answers to interrogatories shall be binding on the party submitting them. This form must be signed by both the subscriber and the firms Contact Person prior to submitting. 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. In determining the number of questions, you can ask, subparts are counted separately. These are used in conjunction with requests for admission. Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. A person who receives interrogatories has 30 days to respond in writing. Get help from an experienced discrimination lawyer. The case settled and I got a lot more money than I expected. 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. But the total number of requests cannot exceed thirty. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. 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. 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. A-5298-07T25298-07T2. Google Translate is an online service for which the user pays nothing to obtain a purported language translation. 21. 34:15-20, Decision of Dismissal (Second Injury Fund), Order for Total Disability with SS Offset (fillable), Order for Total Disability with SIF(fillable), Addendum to Order for Total Disability(fillable), ELECTRONIC CALENDARS, COURTS ON-LINE AND ELECTRONIC FILING FORMS. interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. Sample Interrogatories From Defendants Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. "You," "your" or "your company" means Dentsply. 12. (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. 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. 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. 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. *266 Mr. David A. Rappeport, attorney for plaintiff. Use these sample interrogatories however you like. 0000001427 00000 n hVmO8+t&~wR- ,B3vKSx27GdYJH ) 1. DOCKET NO. 0000001851 00000 n You need to mold them to the facts. Interrogatory No. They quite literally worked as hard as if not harder than the doctors to save our lives. 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). 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. ) FIRST SET OF INTERROGATORIES _____, ) TO DEFENDANT Defendant. ) Pursuant to Fed. 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). 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. 4:17-5(a). 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. 0000006979 00000 n Why do they do it? 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. Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. application/pdf I, I, XXX certify that on this 29th day of the month of October, 2009. 4. 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. Uniform Interrogatories in New Jersey Rule 4 :17-1(b)(2) Cases > > Read More.. "Relevant time period" means the time period stated in paragraph 1 of the Instructions. 17. 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. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. 2 0 obj In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 CN: 10159. 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. 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). 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 . 6. 3. Related Forms and Guidance . 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. Superior Court of New Jersey, Law Division. 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? 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 The PLAINTIFF requests that the DEFENDANT produce the following documents and things in your possession, custody or control in accordance with Rules 26 and 34 of the North Carolina Rules of Civil Procedure for inspection and copy at the offices of 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. In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. 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. "Person" means any natural person, corporation, company, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission, office or other business or legal entity, whether private or governmental. Identify all agreements or contracts between the plaintiff and defendant wrP+:y. Rule 4:17-1. Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. 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). 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 of the California Rules of Court, these interrogatories must not be used until the asking party has But please read the interrogatories carefully and make sure they fit your case. Share sensitive information only on official, secure websites. Answer each interrogatory fully. Official websites use .gov Then draft your discovery and demand answers that fairly and honestly answer the questions. The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun, and vice versa; and the past tense shall include the present tense where the clear meaning is not distorted. See, R. 4:17-1(a). 30 0 obj <> endobj Insurance Carrier Contact form (online): this form to designate a contact person must . 3. 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 This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. State your full name, home address, business address, and occupation.