3. 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. (b) Uniform Interrogatories in Certain Actions. 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. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. <> Answer each interrogatory fully. Toolkit http://www.activepdf.com Use the saved form as a template for future Adjournment Requests. 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. 2 0 obj Objections to Interrogatories, Rule 4:17-6. Well-drafted interrogatory answers can put more money in your pocket. 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 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. 21. 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. In a case deemed complex under rule 3.400 et seq. R. Civ. 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 . DOCKET NO. See, R. 4:17-1(a). Request for Records Inspection: this form must be completed and signed before the Division can release records. Pursuant to Tennessee Rule of Civil Procedure 26.02(5), if any 0000002957 00000 n Sample Plaintiff's Answers to Defendant's Interrogatories. I understand that submitting this form does not create an attorney-client relationship. 0000006225 00000 n CN: 10151. 0000002626 00000 n 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. 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. 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 6. DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. 19. 8/9/97 1. 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 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. Another favorite objection is that the plaintiff bears the burden, so no answer is required, an objection that is beyond silly. Insurance defense counsel often refuses to answer discovery. 0000001288 00000 n N.J.R. 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). Case Management Order. So asking an interrogatory with several questions does not help keep the number down. stream Read them. On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. (Caption) 1. %PDF-1.5 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. You use sample interrogatories because there are some pieces of information you want in every single case. 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. 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. We draft our client's answers to save them the hassle of having to do so and because we want to word the responses in a certain way. 5. Please read through these Interrogatories and prepare your responses, this will save you time Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. 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. The party serving the interrogatories shall furnish the answering party with the original thereof. 0000003390 00000 n uuid:c389e0db-e0fb-49a3-99ce-ba737d89aee6 3.5.2 SP6 (5110) NJ Art of Advocacy - Discovery See Part III: Interrogatories and Requests for Production of Documents. Because the number of requests is restricted without a court order or an agreement among the parties, interrogatories in a complex case should be carefully drafted to request only information that a lawyer cannot find using other discovery mechanisms. It is trite, but you have to digest each word. (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. . 0000006979 00000 n 12. <>>> 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. "You," "your" or "your company" means Dentsply. Fortunately, we were sure that the judge that hears the motion to compel has read these rules. 0000015309 00000 n 3. 0000003987 00000 n Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. 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. 18. 0000000951 00000 n 4:17-5(a). "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. endobj $Kw<8uCyjd2 ]dg`w+Vf};|"8UkT3)yn d"W2=B4oUcFW5L1}!Afm$_nhX!QxnS5Q~h+^ua]3:*. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. 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. > > Read More.. The responding party must answer in writing and under oath. 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. 1. CERTIFICATE OF SERVICE. CN: 10153. The user is on notice that neither the State of NJ site nor its operators review any of the services, information and/or content from anything that may be linked to the State of NJ site for any reason. "Relevant time period" means the time period stated in paragraph 1 of the Instructions. This form can now be e-mailed to the individual district offices. 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. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. "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. Call (804) 251-1620 or (757) 810-5614 today. Accordingly, we suggest serving more than one set. endstream endobj 31 0 obj <> endobj 32 0 obj <> endobj 33 0 obj <>stream 1. Resource Family Information Form (Word form) CN: 10159. "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. (b) It is permissible for interrogatories to include a request for a copy of a document. Don't take the insurer's set of written interrogatories lightly. The State of NJ site may contain optional links, information, services and/or content from other websites operated by third parties that are provided as a convenience, such as Google Translate. 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. REV. Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. "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. Make sure you are not objecting to form interrogatories approved by the court. 1 0 obj Service, Scope of Interrogatories, Rule 4:17-2. responses to first set of interrogatories ELECTRONICALLY FILED - 2018 Mar 15 2:01 PM - GREENVILLE - COMMON PLEAS - CASE#2014CP2304432. 0000040696 00000 n 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* 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." 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. 2009-03-16T23:32:54Z Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. The last case I referred to them settled for $1.2 million. Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. Time to Serve Interrogatories. 9. 4!mU>]3Nn6~p ,5_Rn]`R.nQirvuA+`i&.8ZfS |cg2'~pY>+8u4>)n9wv|aS9)y>P4}/fd`0W2bUOg"~yf;+[?JZjbtt5qr'r4"|D>fYLZCCE+zX9/+3qyq#1$x,8U1UBV(hSwa3>"n.$2=b. {i;6#0O R(VnxTw&:f0L(Y#c{l'tD C]FqC eZ yvm?6=a/DFdrz3 }*S B4,;B@+D\M.F6``CnFwg8#k7"K3T$222LU4iY6@U@pTnb!]1?=g4spG0 `>X=bkKw#>LPb"; Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Rule 4:17-4. 17. Written interrogatories are a useful discovery tool for plaintiffs in all types of tort 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. 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. All rights reserved. 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. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. 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 Art of Advocacy: Preparation of the Case 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). "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. "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. Except as otherwise provided by R. 4:17-4(e), if a party who has furnished answers to interrogatories thereafter obtains information that renders such answers incomplete or inaccurate, amended answers shall be served not later than 20 days prior to the end of the discovery period, as fixed by the track assignment or subsequent order. 5. Bring them in for an appointment to go over the answers. Access from your Country was disabled by the administrator. 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. #+wmoSd&Vx7H3"uk]v0 A"`>MB-u6`[dxd;X!CfD3w\BT!g#WQILYgUXTt!2VpPvYpogZzS1(J |J/-T%w5m 1l05Xgh}nH.t`(e@Q:gL^6pVIE)D- {5hMKdzo`-P2d+!Bc~ RTR+[c(GC7N6;4Vl[ P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. Follow instructions on the form. to schedule a free consultation with our team. previous. Number of Copies Served; Form of Interrogatories. 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). We have a number of samples in all different types of tort cases above. If an interrogatory has five related subparts, it will be counted as five interrogatories. It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline. We have spent a lot of time fine-tuning our interrogatory questions over the years. "Communication" means any disclosure, transfer, or exchange of information or opinion, however made. 22. 4. INTERROGATORIES 1. 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. CN: 10159. 3. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. at fniemann@hnlawfirm.com or call him toll-free at (855) 376-5291. As suggested above, you will often get this response even when you using template questions employed by the court. 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. Next, the interrogatories will likely ask . Adobe Acrobat 8.13 Paper Capture Plug-in *266 Mr. David A. Rappeport, attorney for plaintiff. It is not a pretty sight. "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. Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) 0000037811 00000 n Privilege Log. 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. Directory of Superior Court Deputy Clerk's Offices/County Lawyer Referral and Legal Services Offices. R. Civ. Interrogatories in Nursing Home Negligence Cases. We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers, Sample Discovery Requests in Personal Injury Lawsuits. FOR PLAINTIFF UNITED STATES OF AMERICA: Carl Schnee UNITED STATES ATTORNEY FOR THE DISTRICT OF DELAWARE, By: _________________________________ Judith M. Kinney Assistant United States Attorney U.S. Attorney's Office 1201 Market Street, Suite 1100 Wilmington, DE 19801 (302) 573-6277 Delaware Bar No. Search for another form here. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. The case settled and I got a lot more money than I expected. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. 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. Objections made thereafter shall not be entertained by the court. 99-005 (MMS) PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. 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. So both the client and the lawyer are usually involved in preparing these written responses. Use these sample interrogatories however you like. A .gov website belongs to an official government organization in the United States. "Including" means including, but not limited to. The interrogatories may include a request, at the propounder's expense, for a copy of any paper. CN: 10160. The contact form sends information by non-encrypted email, which is not secure. 0000040914 00000 n -Read Full Disclaimer. INTERROGATORIES TO PLAINTIFF Ans. _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. Limitation of Interrogatories. 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. and CONSTANCE COLEMAN, Plaintiffs-Appellants, . 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. Written responses from a defendant can help narrow down the issues in a case. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo first. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. Browse Workers Compensation forms and publications below. 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. (c) In response to any interrogatory, you are permitted to provide copies of business Save the form onto your computer byhitting Save As. Princeton, New Jersey 08542-0627 Tel. 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. 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. 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. These questions are referred to as "Interrogatories". 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. 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