State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. Use [ edit] "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. Follow instructions on the form. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. Interrogatories are written questions answered under oath. Part IV - Rules Governing Civil Practice in the Superior Court, Tax Court and Surrogate's Courts, Rule 4:16 - Use of Depositions; Objections; Effect; Errors and Irregularities, Rule 4:18 - Discovery and Inspection of Documents and Property; Copies of Documents. 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. 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. Identify all agreements or contracts between the plaintiff and defendant 1. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 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. (b) Uniform Interrogatories in Certain Actions. (c) In response to any interrogatory, you are permitted to provide copies of business 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. B P Z b G H X ` m n u h7 h. The interrogatories may include a request, at the propounder's expense, for a copy of any paper. 16. 7. 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 . Have ever seen someone running away from their answers to discovery at trial? 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. 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; Insurance Carrier Contact form (online): this form to designate a contact person must . Fillable PDF 2. 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. 2013-04-26T13:58:46-05:00 Another tactic that leads to quality information about defendant's case is using alternative interrogatories. A. This is a checklist you might want to consider in providing answers to this discovery: There is one more really important thing to keep in mind. 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. "You," "your" or "your company" means Dentsply. endobj HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 endstream endobj 31 0 obj <> endobj 32 0 obj <> endobj 33 0 obj <>stream 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. Decided February 14, 1963. Use the saved form as a template for future Adjournment Requests. 0000004028 00000 n Attorneys hate taking positions before trial. endstream endobj startxref to schedule a free consultation with our team. Many use this objection to the simplest of questions. The list below contains the sample NJ divorce documents discussed above. previous. Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. 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. 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. 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. 4 0 obj 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. Written responses from a defendant can help narrow down the issues in a case. 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. 8/9/97 1. 8. "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. 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. The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. Form, Service and Time of Answers, Rule 4:17-5. 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. 4. Allstate GEICO SUPERIOR COURT OF NEW JERSEY. 18. 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. "Including" means including, but not limited to. "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. 0000006248 00000 n hbbd``b` $c`b - V0P2$30RNg You use sample interrogatories because there are some pieces of information you want in every single case. A-4540-16T4 JI SUNG KIM, Plaintiff-Appellant, v. PAUL P. KOBLISKA, Defendant-Respondent. 2. Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. 19. [Source: NJ Court Rules, Appendix II - Interrogatory Forms, Form A(2), #4.] 10. Don't take the insurer's set of written interrogatories lightly. 0000037811 00000 n <> Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. 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. New Jersey Divorce - Discovery - Interrogatories State: New Jersey Change state Control #: NJ-021B-D Instant Download Buy now Available formats: Word | Rich Text Free Preview Description Related Forms How to Guide All forms provided by US Legal Forms, the nations leading legal forms publisher. *266 Mr. David A. Rappeport, attorney for plaintiff. Limitation of Interrogatories. 5. $@ (&*,RLo0dNevce1%9%CYD}sTwY,Ps`)2ro O}+%=^g[V9zvhbgq1xpBk +C:@D7D2:L0 'h00X@,ggZ `( 4@xK?Hp4p$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 Just think about what you are trying to prove at trial and explore those issues. 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. Well-drafted interrogatory answers can put more money in your pocket. State your full name, home address, business address, and occupation. "Relevant time period" means the time period stated in paragraph 1 of the Instructions. 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. "Dealer" means any person that distributes any dental products of any other person or purchases or acquires any such product for the sole purpose of reselling such products to any other person, such as a dental laboratory, dentist, dental school or government entity. Sample Plaintiff's Answers to Defendant's Interrogatories. But, either way, get them out quickly. 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. I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424. R. Civ. 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. Figure out how long you have to respond. Package contains both the Designation of Contact form and Subscriber application form. Write in plain English and keep in mind that these responses can be read to a jury. 1. IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. (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. Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. 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. (Caption) 1. These are sample written questions that you might receive in your divorce. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. 0000049177 00000 n N.J.R. DEJON WELCOME, CIEMON MOUZON. 0000007135 00000 n Don't object just because you don't want to answer the question and try to keep the objection as narrow as possible. Contact the experienced family attorneys at Arons & Solomon Divorce Lawyers today for legal assistance. 0000015309 00000 n % The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. Answer each interrogatory fully. 0000040696 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 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. "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. APPELLATE DIVISION. 15. Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action. 11. %PDF-1.5 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. INTERROGATORIES TO PLAINTIFF Ans. Washington, DC 20005 . It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline. 0000000951 00000 n Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. 2. 0000006438 00000 n The following Interrogatories are served upon you pursuant to Fed. 2. You need to mold them to the facts. 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). It can be either in the form of a question (usually contention interrogatories), or they can direct the answering party to supply accurate information that is described. In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. 2009-03-16T23:32:54Z As a result, we make a lot of diving impossible catches but miss too many fly balls. They quite literally worked as hard as if not harder than the doctors to save our lives. The party serving the interrogatories shall furnish the answering party with the original thereof. Uniform Interrogatories in New Jersey Rule 4 :17-1(b)(2) Cases > > Read More.. R. Civ. Questions About Marriage and Marital History. 0000002957 00000 n 6/2014. In most jurisdictions, parties may serve 30 written questions. But you are making a mistake if you do not craft interrogatories that are specific to your case. Art of Advocacy: Preparation of the Case NEW JERSEY'S CIVIL COURT PROCEDURES UPDATED AS OF JANUARY 2011 NEW JERSEY INSTITUTE OF CONTINUING LEGAL EDUCATION One Constitution Square, New Brunswick, N.J. 08901-1520 (732) 249-5100 The New Jersey Institute for Continuing Legal Education Celebrating over 40 years of service to the bench and bar 4:46-2(c) > > Read More.. MOVING PAPERS 2. 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. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. This form must be signed by both the subscriber and the firms Contact Person prior to submitting. Make your practice more effective and efficient with Casetexts legal research suite. 0000001851 00000 n The attorneys at Hanlon Niemann have decades of complex trial experience ready to work for you. The case settled and I got a lot more money than I expected. An official website of the United States government. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. %PDF-1.6 % But you have to make sure the client owns the language. So asking an interrogatory with several questions does not help keep the number down. 5. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. State your full name, your present address, and date of birth. Think about the hard questions that you would like to get answers to read to a jury. 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. Princeton, New Jersey 08542-0627 Tel. Browse Workers Compensation forms and publications below. Order to Show Cause and to Appoint a Law Guardian with Care and Supervision. Rule 4:17-1. Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. 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. 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. Interrogatories in Nursing Home Negligence Cases. 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. 9. Any challenge to the certification of due diligence will be deemed waived unless brought by way of motion on notice filed and served within 20 days after service of the amendment. Copyright 1999 2023 GoDaddy Operating Company, LLC. CN: 10151. hJN)OdJBf1GhE wUV4lr1L},rQv'Kwr`qkwFZR&ci1Q I am so grateful that I was lucky to pick Miller & Zois. 4:17-5(a). Objections to Interrogatories, Rule 4:17-6. 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE But please read the interrogatories carefully and make sure they fit your case. 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 . 3. endobj Part VII offers additional Model Discovery. 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). If you have any questions about New Jersey contract law and contract litigation, then please contact Fredrick P. Niemann, Esq. 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. 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. Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) 2013-04-26T13:58:46-05:00 hVmO8+t&~wR- ,B3vKSx27GdYJH ) The next three sample sets are sent throughout the course of discovery. (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. 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 "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. wrP+:y. Draft your answers. 0000003166 00000 n All amendments to answers to interrogatories shall be binding on the party submitting them. interrogatories, please note: (a) You are required to furnish all information available to you, your agents, employees and attorneys.

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