1 0 obj If the document is commercially printed or published, the name and address of the printer or publisher are required. /Type/Page In addition to your time at work, do you have any other work-related obligations and commitments? These cookies do not store any personal information. If you have one, just log in and find a suitable sample, download it, and fill it out. Interrogatories as follows: General Objections 1. 81. ANSWER: 2. When practicingfamily lawhere in New Jersey, one of the most fact sensitive areas for an attorney to handle is a child custody case. This form, Discovery Interrogatories from Plaintiff to Defendant with Production Requests, is a sample form of interrogatories for the Plaintiff in a Divorce action to ask the Defendant. 12:235-3.8(d)), and occupational exposure cases (See N.J.A.C. If, for example, you subsequently learn that your spouse concealed a bank account from you, the court probably would not reopen the matter and allow you to receive your share of that asset if you did not serve Interrogatories. REQUEST FOR ADMISSION 10: Admit That MVP . 40. We are an independent branch of government constitutionally entrusted with the fair and just resolution of disputes in order to preserve the rule of law and to protect the rights and liberties guaranteed by the Constitution and laws of the United States and this State. 0 Will the Defendant/Plaintiff rely on expert testimony at time of trial? 24. In the past, did the child/children display or reveal any unusual habits, abnormal tendencies or erratic behavior? Agreements, LLC Another example of where special interrogatories would be useful is a situation where there is a dispute over ownership and control of an area. For example, a plaintiff may send interrogato Has the Defendant/Plaintiff ever struck the child/children within the past 24 months? State the name and address of the Defendants/Plaintiffs current physician. SDNY Pro Bono Panel Sample Forms/Documents. Center, Small Main (206) 267-7100 /Info 65 0 R << Ms. Burk focuses her practice in the representation of employers, self-insured companies, and insurance carriers in workers compensation defense matters. See, R. 4:17-4(a). Please identify each person who answer these interrogatories and each person (attach pages if necessary) who assisted, including attorneys, accountants, employees of third party entities, or any other person consulted, however briefly, on the content of any answer to these interrogatories. 89. Is any person(s) known to the Defendant/Plaintiff to possess knowledge of any relevant facts relating to this case, or any expert witness(es) related by blood, marriage, law, contract, employment or in any other way to the person(s) of their counsel, to whom these questions are addressed: 7. /F0 71 0 R Do you intend to provide religious training for the child/children; 41. /Size 73 Fax (206) 267-7099, Committees (Common Interest & Service Groups), Pro Bono Opportunties & Volunteer Services. 27. 9. (j) interest in childs/childrens welfare; (n) how well suited to care for child/children; (p) range of interest outside of profession, business or occupation; (b) the name of person and relationship to you; (b) when it occurred, giving dates of admission and discharge; (e) the relationship of the person to you. If you omit information (for example, the name of a witness) you may be prevented from presenting the information or having that witness testify at the time of trial. Click on Buy Now button to access the sign up page. The Court's name. 58. Often, information that was not available to you, that you overlooked, or that you simply did not recall at the time of your original answers can appear to your spouses attorney or the judge to be a deliberate withholding of information which can have a significant adverse impact on your case. 68. Has the Defendant/Plaintiff ever been examined or treated by a psychiatrist or psychologist? Real Estate, Last by reference to the case information statement required by R. 5:5-2. Identify all written documents that you authored in full or part, regarding the plaintiff. 35. 12:235-3.8(g), interrogatories may be allowed in other cases, upon motion, for good cause shown. trailer h]o0/ R)-i$[!.hH"`[w1jhsl$0di&Da!&B1/A!Q License Agreement for Deed, Promissory The answer is, no, you may not.That answer must either permit inspection of the requested information or object to the production of the information for a specific reason. shall contain a description thereof. Has the Defendant/Plaintiff consulted with any other physician or practitioners of the healing arts in the past 36 months? In the event that you have an objection to any of the foregoing Interrogatories or Request for Production of Documents, please: (1) State the nature of the objection; and (2) if the ground is attorney-client privilege or attorney work-product, state the facts relied upon in support of the objection. This website uses cookies to improve your experience. Does the Defendant/Plaintiff, or any other member of your household currently smoke or smoked in the last five (5) years? New Jersey has adopted rules governing practice in Chancery Court 11. Estate, Public endobj If we represent the spouse who has had control of the assets, a full disclosure of the assets protects you against a future attempt to modify the Agreement or Judgment on the basis that you concealed assets. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); This site uses Akismet to reduce spam. If the information is not known to you or you are estimating, that should be clearly indicated in your answer. Business Packages, Construction (a) to what extent and for what types of infractions; (k) interest in remaining a residence of the State of New Jersey. 17. New Jersey Discovery Interrogatories from Plaintiff to Defendant with New Jersey Discovery Interrogatories From Plaintiff To Defendant With Production Requests, Living 0000007751 00000 n Special Interrogatories may be used to obtain critical information of a discovery or factual nature that either party needs to prove its case. of Attorney, Personal 0000001047 00000 n This site is maintained by the U.S. District Court - District of New Jersey, IT Department. < '0:\A C|SA?4z0HR/H)wnW``9i?V FF 5` You must explain why you object. Agreements, Bill of /Filter/LZWDecode>> 16. 2 Answers from Attorneys. 4:17-2 - Time to Serve Interrogatories. 6/22. of Business, Corporate ATTORNEY ADVERTISING Copyright 2023, Stark & Stark. Attorneys for and on behalf of the Plaintiff, Dated: By: _____________________________________________ GENERAL INSTRUCTIONS. Under N.J.A.C. Questions in this set follow up on and narrow focus of . Does the Defendant/Plaintiff tolerate the use of drugs in others? Does the Defendant/Plaintiff use drugs or have you used drugs in the past 10 years? The defendant in a New Jersey Rule 4:17-1(b) action is deemed automatically served with uniform interrogatories upon service of the complaint. RULE 4:17 - Interrogatories To Parties. Agreements, Letter These cookies will be stored in your browser only with your consent. The interrogatories may include a request, at the propounder's expense, for a copy of any paper. In terms of (1) strong, (2) moderate, or (3) weak, describe the Defendant/Plaintiff as to the following categories: 14. Identifying information of witnesses. The list below contains the sample NJ divorce documents discussed above. The questions are designed to obtain more information about your case. CCP 2030.310-2030.410. So, can you refuse to answer interrogatories? Attorney, Terms of << Geaneys New Jersey Workers Compensation Manual, A Guide to Interrogatories and Their Importance in the Workers Compensation Practice, Section 20 Settlement Versus Order Approving Settlement, Answers to Common Questions Regarding Partial Permanent Disability Awards in New Jersey, Governor Passes Bill Increasing Compensation for Workers Comp Hand And Foot Injuries. US Legal Forms is really a unique platform where you can find any legal or tax form for filling out, including New Jersey Discovery Interrogatories from Plaintiff to Defendant with Production Requests. (f) what was the child/childrens response? Guide, Incorporation 0000000016 00000 n Sale, Contract Objections may be made to all discovery questions if the questions are not relevant, or likely to lead to the discovery A Request for Interrogatories will ask the opposing party a series of questions to help aid in the fact finding process of the case. Can you perceive any disadvantages to the child/children if custody were given to you? %%EOF Notes, Premarital The term Defendant as used herein refers to ___________________________. 8. Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. Defendant denies the allegations in Paragraph 15 of the Complaint. A. Don't waste your requests writing You must answer each interrogatory separately and fully in writing under oath, unless you object to it. C. All Interrogatories require an answer even if the context of the question seeks only an affirmative response and the response you intend is not affirmative. Adobe PDF Viewer: www.adobe.com. 67. 0000004843 00000 n You may object to Form Interrogatories, but be careful to use the proper objection. 10. 54. Incorporation services, Living Resource Family Information Form. Request for Interrogatories is a common request in the Discovery process of a lawsuit. State (a) the name and address of any person, including any person or party answering these interrogatories, who has made a statement regarding this lawsuit or the subject matter of this lawsuit; (b) whether the statement was oral or in writing; (c) the date the statement was made; (d) the name and address of the person to whom the Maura Burk, Esq. >> Essentially, these interrogatories are seeking information regarding any new injuries, incidents, or treatment since the entry of the prior Award. r. /Subtype/TrueType packages, Easy Order Rule 4:17 - Interrogatories to Parties. services, For Small We'll assume you're ok with this, but you can opt-out if you wish. In a slip and fall case, the main issue is usually whether the property owner -- or whoever was charged with maintaining the property -- failed to take reasonable steps to prevent the plaintiff's accident. 6. track and within 120 days from said date in actions assigned to the standard Law Firm of Ted Roco for Bank of New Debt, 1 Kimble St, Boston, MA 02222on (date)_ June 30, 2012. If a legal objection is made with respect to any Interrogatory, you should set forth the specific reason for such objection. The term Person may be set in lower case throughout the Instructions, Definitions and Interrogatories. Describe in detail the floor plan of the Defendants/Plaintiffs residence, its condition, its furnishings, the structure in which it exists, and the surrounding neighborhood. of relevant evidence. When a party to a civil case needs to get information from the other side, she can serve the other side with written requests called "discovery requests.". View Ohio Partial Satisfaction and Release of Land Installment Contract, View Ohio Correction and Ratification of Notice of Extension of Term of Pipeline Right of Way Agreement, View Ohio Durable Limited Power of Attorney, View Ohio General Unlimited Power of Attorney. Name Change, Buy/Sell Rule 4:17-1. You must sign your answers and objections. the truth before questioning begins. Does the Defendant/Plaintiff believe in corporal punishment by parents against children? Estates, Forms 6. The specific deadline depends on the procedural rules of the court or agency where you filed an action. The interrogatories may include a request, at the propounder's expense, for a copy of any paper. (d) the name and address of the Court in which the proceedings were initiated; (b) name, specifically those beverages which you consume; (a) the purposes for which these drugs were prescribed; (a) the name and address of each physician or practitioner; (e) the nature of the treatment and the duration thereof. 26. Agreements, Corporate 4. Agreements, Corporate (a) Generally. Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. These Sample Interrogatories do not change any court requirements. Interrogatories are a series of written questions submitted by one party in a lawsuit to the opposing party. If only a portion of an Interrogatory cannot or will not be answered, provide the fullest answer to the Interrogatory and thereafter specifically set forth (a) the fact that the answer is incomplete and (b) the reason or grounds for any omission and/or refusal to complete. The rules cited in Rule 5:5-1 of the Chancery Court Contents hide. 0000034244 00000 n Document shall mean the original and any copy, regardless of origin or location, of any book, pamphlet, periodical, letter, memorandum, telegram, report, records, study, handwritten note, working paper, chart, photograph, index, tape data sheet or data processing card or any other written, recorded, transcribed, punched, taped, filmed or graphic matter, however produced or reproduced, to which you have had access. 2. 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. (a) why, giving specific reasons. Plaintiff brought her vehicle to a complete stop due traffic stopped in front of her. Thus, if any answer is left blank, it shall be deemed to be none.. Depositions answer the question once the objection is stated. The answers or responses are usually due between 20-30 days. Neither the interrogatories nor the answers thereto shall be filed unless the court so directs at the pre-trial conference or trial. to enter an order granting the extension to protect your rights. of Business, Corporate Nor does Plaintiff concede that any of the information sought is admissible, material or relevant in these proceedings. Was a diagnosis ever made of the Defendants/Plaintiffs mental or emotional condition? Practical Advice in New Jersey Workers' Compensation. 78. track. 2. 0000002323 00000 n Virtually all states have adopted a version of civil procedure rules which include rules dealing with discovery. Agreements, LLC Rule 5:5-1 of the Chancery Division provides: Except for summary actions and except as otherwise provided by law When we send the Interrogatories to you, we will normally ask for your answers within 3 days to allow us an additional 30 days to review the answers, meet with you to discuss them if necessary, and prepare and submit the answers in final form. questions to ask the other side. Has the Defendant/Plaintiff attended educational institutions higher than high school? If you have additional . Interrogatories are questions that let you find out information from the Plaintiff about the case. Elsewhere on this website, we talk about the importance of forcing defendants to provide meaningful answers to interrogatories, requests for the production of documents, and other discovery responses and requests. 61. Word (DOC) without forms|Word (DOC) with forms|Adobe PDF, If you experience difficulty viewing either of these files please first ensure you are using the latest version of the software used to view them. Operating Agreements, Employment 60. A-Z, Form 61 0 obj Learn more about our Diversity & Inclusion initiatives. Petitioners are asked to identify any subsequent employment held since the entry of the prior Award, including job duties at any new / subsequent positions. 0000000838 00000 n My Account, Forms in 38. It is worth noting that any re-opener application must be filed within two years of the last date of payment made to petitioner, pursuant to N.J.S.A. Interrogatories not stricken must be answered within the unexpired period of the sixty (60) days that remained when the notice of motion was served, or as the court directs. (b) what you generally do/did during such time. You also have the option to opt-out of these cookies. If you are looking for a lawyer to discuss this with further, please do not hesitate to contact my law firm. (S or C-Corps), Articles Annex hereto a copy of each written report (or detailed resume if report was oral) of every expert retained or consulted by the Defendant/Plaintiff including any person who has conducted an examination pursuant to R.4:9 (or as it may be amended) whether or not you intend to use such expert at time of trial. Has the Defendant/Plaintiff been treated for drug use? 37. In this instance, Respondent should consider filing a Motion for Special Interrogatories seeking further, and specific information, from the injured worker about the prior out-of-state accident, including names and addresses of all treating physicians, the nature of the injury, etc. Oral Communication shall mean any utterance heard by another person, whether in person, by telephone or otherwise. startxref Questions in sets 1 - 3 are designed like a funnel to narrow down responses from defendants. . 91. SmartRules only services accounts in the United States and customers with special access needs from abroad. N.J.R. Directive, Power off Incorporation services, New Jersey Divorce - Discovery - Interrogatories, Identity These requests might include: Interrogatories, which are written questions about things that are relevant or important to the case. Fill your name in as the Requesting Party. 31. List questions are interrogatories you usually must answer in the form of a list. for Deed, Promissory By providing information in response to these Interrogatories, Plaintiff does not concede the accuracy of Defendant's definitions, assumptions or allegations. & Estates, Corporate - If you require extra time to respond to discovery, you should ask 51. When was the Defendants/Plaintiffs last physical examination? The interrogatories are available in both Word (DOC) and Adobe PDF format. hbbd``b`z$'/ r$vH~,F|> + Page 6/11 Interrogatories 4 sample interrogatories from plaintiff and defendants answers in products liability case Answers to Those written answers are called Answers to Interrogatories. 44. Sample Interrogatories. (a) the date on which you observed the incident; (b) the law enforcement authority that you reported the incident to; (c) any evidence (i.e. 7. pursuant to R. 4:11 et seq. For example, if petitioner files an occupational Claim Petition on January 1, 2022, and his response to Inquiry Number 10 states that he became aware of his claimed injuries and their alleged relationship to employment at any time prior to January 1, 2020, Respondent should utilize petitioners Answers to seek a dismissal of the claim pursuant to N.J.S.A. If so, what are they? Identify the specific statements or . (c) what, if anything, did you do about it. Often the interrogatories served by petitioner asks respondent to identify whether petitioner was an essential worker. Liens, Real of Directors, Bylaws 4:17-8(b). Thank you. Under the Rules of the Workers Compensation, you must include objections with answers to interrogatories. Seattle, WA 98101 The attorneys who sent them to you already have a legal determination that you do owe it. Interrogatories Interrogatories are written questions that are sent by one party to another.Requests for production are the means by which you can ask the other party to make copies of documents, photographs, records, etc. Begin hassle-free! (iv) Reference to any such document by any witness or by your attorney for the purpose of cross-examination, to refresh the recollection of a witness, to impeach the credibility of any witness or for any other purpose. %%EOF Does the Defendant/Plaintiff feel that religious training has any importance in the up-bringing of the child/children and, if so, why. 59. referred to in pleadings (R. 4:18-2) which shall be permitted as of right. When we send the Interrogatories to you, we will normally ask for your answers within 3 days to allow us an additional 30 days to review the answers, meet with you to discuss them if necessary, and prepare and submit the answers in final form. Service, Contact 69. Personal injury interrogatories are often requested and completed as part of various forms of discovery that is conducted during the litigation process. This website uses cookies to improve your experience while you navigate through the website. Business. 86. In this instance, interrogatories could be served seeking to obtain deeds and/or tax records and other documents to demonstrate ownership and control, or lack of ownership or control. 0 oral questioning, document production and admissions requests are generally endstream endobj 27 0 obj<> endobj 29 0 obj<> endobj 30 0 obj<>/Font<>/ProcSet[/PDF/Text]/ExtGState<>>> endobj 31 0 obj<> endobj 32 0 obj<> endobj 33 0 obj[/ICCBased 39 0 R] endobj 34 0 obj<> endobj 35 0 obj<> endobj 36 0 obj<>stream (a) the name and address of the religious institution with which you are affiliated; (b) the frequency with which you attend religious services; (b) what plans do you have to remove the child from the State of New Jersey; (c) describe what you have done to carry out said plans. Handbook, DUI Estate, Last Take the time to make sure your answers are correct and truthful. 0000004304 00000 n State the date of the physical examination, the physician who examined you. age of 18, and including parties or experts, as of course may be taken (a) treatment you receive, if any, specify; (c) the nature and extent of the striking; (d) if the Plaintiff was injured and, if so, to what extent; (e) if the Plaintiff received medical treatment and if so, from whom, giving name and address; (g) who was present at each striking, giving names and addresses. To obtain this information, the Plaintiff can pose interrogatories to the Defendant. If you want to challenge that you'll have to read a copy of the arbitration rules. of discovery shall be prescribed by case management order. The term You or Your may be set in lower case throughout the General Instructions, Definitions and Interrogatories. /Length 5 0 R Templates, Name I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Forward any reports (or resumes or oral reports) received by the Defendant/Plaintiff after these answers to interrogatories were served. Records, Annual NEW! (S or C-Corps), Articles There is very little guidance on who is an essential employee, so this is actually a complex legal question as proximity to the public is not defined in the Essential Employee Law. Service, Scope of Interrogatories. I hope these sample workers compensation interrogatories save you time and help you maximize your claim's value. Z~vYk2cI'i1nlYI>W-uiGJj>)u. Supreme Court Decision Provides Overview of NJ Insurance Fraud Prevention Act and the NJ Workers Compensation Fraud Act, A Practitioners Guide to Prior Injuries and Credits, Supreme Court Finds Non-Waivable Duty on the Part of Insurance Brokers to Provide Notice of Available Coverage for LLC Members, Appellate Division Reverses Award of 20% Counsel Fee on Order for Medical and Temporary Disability Benefits and Permanency Benefits. If so, who? Pursuant to Rule 6:4-3 of the New Jersey Rules of Special Civil Part Procedure, Defendant Jane Doe submits the following answers to Plaintiff Midland Funding set of Interrogatories. If we represent the spouse who has not had access to the assets or finances of the marriage, the answers to Interrogatories are one way that we can obtain a disclosure of the marital assets and protect you in the event your spouse has concealed or failed to disclose assets. (c) did you ever discuss it with her/him and when; (d) what was said during this discussion. Pursuant to Rules 4:17-4 and 4:17-5 of the New Jersey Rules of Court, Defendants Maxus Energy Corporation ("Maxus") and Tierra Solutions, mc. List all former names and when you were known by those names. 61 12 served by any party as of course pursuant to R. 4:17. %PDF-1.6 % The demand for discovery included standard form interrogatories, supplemental interrogatories, and a notice to produce, which demanded plaintiff produce executed authorizations to obtain his medical and prescription records. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. In respect to the Plaintiff, compare yourself as to the following categories in terms of being (1) equal, (2) superior, (3) inferior: 15. What is the present state of the Defendants/Plaintiffs health? Certification of Insurance (filed with Complaint and Answer) Confidential Litigant Information Sheet (filed with Complaint and Answer) Depending on the complexity and issues in dispute in your case you will encounter various other documents before and after executing the . These sample questions are provided as examples in a fictitious case: Has the Defendant/Plaintiff ever been charged with driving a motor vehicle either under the influence of drugs, under the influence of alcohol or driving while impaired? 34. Order Specials, Start Download the document by choosing the preferred format (.docx or .pdf). You are required to answer these interrogatories separately and fully in writing, under oath. Specials, Start