1. "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. Use, Filing and Effect of Interrogatories. Figure out which questions are objectionable. -Read Full Disclaimer. 2. Decided February 14, 1963. (c) In response to any interrogatory, you are permitted to provide copies of business "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. 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). State your full name, your present address, and date of birth. 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. 55 0 obj <>stream DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. 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. %%EOF 0000004058 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; _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE They quite literally worked as hard as if not harder than the doctors to save our lives. Written interrogatories are a useful discovery tool for plaintiffs in all types of tort cases. Resource Family Information Form. 0000038018 00000 n Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. 1. 4. interrogatories, please note: (a) You are required to furnish all information available to you, your agents, employees and attorneys. In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. 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. Call me for a free consultation and help with responding to the requests for information. 14-36 (relating to strike). Limitation of Interrogatories. Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. 2. 20. These are sample written questions that you might receive in your divorce. Ans. 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. We have a number of samples in all different types of tort cases above. So if you can pin down what the arguments will be, you will be in a much better position to structure your case effectively. Figure out how long you have to respond. "You," "your" or "your company" means Dentsply. Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action. 4. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo Rule 4:17-4. 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. (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. 0000007135 00000 n to schedule a free consultation with our team. An official website of the United States government. 0000006438 00000 n HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 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). 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. 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. The attorneys at Hanlon Niemann have decades of complex trial experience ready to work for you. SUPERIOR COURT OF NEW JERSEY. So both the client and the lawyer are usually involved in preparing these written responses. "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. It is trite, but you have to digest each word. Ans. 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. 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. Proc. (Caption) 1. A certification of the amendments shall be furnished promptly to any other party so requesting. 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? If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. 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. 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. I, I, XXX certify that on this 29th day of the month of October, 2009. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. 0000048970 00000 n 2 0 obj 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 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. Copyright 1999 2023 GoDaddy Operating Company, LLC. Identify all agreements or contracts between the plaintiff and defendant uuid:c389e0db-e0fb-49a3-99ce-ba737d89aee6 This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. But you are making a mistake if you do not craft interrogatories that are specific to your case. 2. This form must be signed by both the subscriber and the firms Contact Person prior to submitting. Directory of Superior Court Deputy Clerk's Offices/County Lawyer Referral and Legal Services Offices. R. Civ. (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. Defense counsel in a case recently refused to answer discovery because the defendant thought three sets of requests for admission and interrogatories were just too much. 0000006685 00000 n Most states allow 30 days to respond (twenty-five in federal court under Rule 33). Draft your answers. Think about the case individually. Use [ edit] This form can now be e-mailed to the individual district offices. No agreement, understanding, or stipulation by the Department of Justice or any of its representatives purporting to modify, limit, or otherwise vary these interrogatories shall be valid or binding on the Department of Justice unless confirmed or acknowledged in writing (or made of record in open court) by a duly authorized representative thereof. endstream endobj 31 0 obj <> endobj 32 0 obj <> endobj 33 0 obj <>stream 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. Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. 8. 0000006248 00000 n First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. 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. 0000006979 00000 n 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. Then draft your discovery and demand answers that fairly and honestly answer the questions. %PDF-1.5 % While the Interrogatories you receive may not be exactly like these, they will be substantially similar. But please read the interrogatories carefully and make sure they fit your case. R. Civ. The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 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. DOCKET NO. 0000002957 00000 n of the California Rules of Court, these interrogatories must not be used until the asking party has trailer << /Size 549 /Info 514 0 R /Root 520 0 R /Prev 146835 /ID[] >> startxref 0 %%EOF 520 0 obj << /Type /Catalog /Pages 517 0 R /Metadata 515 0 R /OpenAction [ 522 0 R /XYZ null null null ] /PageMode /UseNone /PageLabels 513 0 R /StructTreeRoot 521 0 R /PieceInfo << /MarkedPDF << /LastModified (D:20020103201212)>> >> /LastModified (D:20020103201212) /MarkInfo << /Marked true /LetterspaceFlags 0 >> >> endobj 521 0 obj << /Type /StructTreeRoot /RoleMap 43 0 R /ClassMap 46 0 R /K 352 0 R /ParentTree 497 0 R /ParentTreeNextKey 14 >> endobj 547 0 obj << /S 335 /L 416 /C 432 /Filter /FlateDecode /Length 548 0 R >> stream If you believe your employer decided against promoting you because of a discriminatory reason, you should talk to the attorneys at Swartz Swidler. Follow instructions on the form. Part VII offers additional Model Discovery. Interrogatories in Nursing Home Negligence Cases. Secure .gov websites use HTTPS Read them. "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. 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 and CONSTANCE COLEMAN, Plaintiffs-Appellants, . REV. 7. The following Interrogatories are served upon you pursuant to Fed. The list below contains the sample NJ divorce documents discussed above. These are used in conjunction with requests for admission. The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. (We do too.) "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. %PDF-1.3 % hbbd``b` $c`b - V0P2$30RNg We have spent a lot of time fine-tuning our interrogatory questions over the years. hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 "Prefabricated artificial teeth" or "teeth" means any prefabricated (as opposed to dental laboratory or dentist constructed) product used in a denture or as an implant to replace one or more natural teeth. 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. These questions are referred to as "Interrogatories". Order to Show Cause and to Appoint a Law Guardian with Care and Supervision. 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. Save the form onto your computer byhitting Save As. 3. 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. Fillable PDF 14. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. 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. Attorneys hate taking positions before trial. For any interrogatory or part of an interrogatory which you refuse to answer under a claim of privilege, submit a sworn or certified statement from your counsel or one of your employees in which you identify the nature of the information withheld; specify the grounds of the claimed privilege and the paragraph of these interrogatories to which the information is responsive; and identify each person to whom the information, or any part thereof, has been disclosed. Make sure you are not objecting to form interrogatories approved by the court. "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. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. 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. stream 1. N.J.R. 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. 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. 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. 15. 0000015309 00000 n Hb```f`` If you have any questions about New Jersey contract law and contract litigation, then please contact Fredrick P. Niemann, Esq. 7. 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. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. State your full name, home address, business address, and occupation. Fortunately, we were sure that the judge that hears the motion to compel has read these rules. 0000003390 00000 n 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. endobj endobj Think about the questions that box in the defendant (in one direction or the other). Please read through these Interrogatories and prepare your responses, this will save you time 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. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. Interrogatories are written questions answered under oath. They are just looking for creative ways to circumvent answering discovery. (Update: Yep, that is what happened!). 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. I understand that submitting this form does not create an attorney-client relationship. 2. The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. See, R. 4:17-4(a). 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. 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. Insurance Carrier Contact form (online): this form to designate a contact person must be completed by every insurance carriers and self-insurer authorized to do business in NJ. Hurley v. The Atlantic City Police
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