With whom do you currently live/reside? 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. Records, Annual You must sign your answers and objections. %%EOF The defendant might send the plaintiff interrogatories such as: Please list all damages that you claim as a result of the alleged defamation, including type of damages, monetary value, and any supporting documents. /E 32078 by leave of court for good cause shown except for production of documents Did the Defendant/Plaintiff ever physically cause any harm to the child/children by pushing, shoving, tripping, spitting on or in any related way? UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY . Insurance information. endobj We use cookies to improve security, personalize the user experience, enhance our marketing activities (including cooperating with our marketing partners) and for other business use. In terms of (1) strong, (2) moderate, or (3) weak, describe the Defendant/Plaintiff as to the following categories: 14. of Sale, Contract Are you aware of any defect or deficit in the Plaintiffs character and personality? >> 65. is a Shareholder in Capehart Scatchards Workers Compensation Group. 71. 45. endobj The plaintiff must give you responses to the request for interrogatories within 45 days of when you mailed the request. However, it is equally important that you assist us by calling any changes to our attention. Word (DOC) Viewer: www.microsoft.com/download We also use third-party cookies that help us analyze and understand how you use this website. or rule, discovery in civil family actions shall be permitted as follows: (a) Interrogatories as to all issues in all family actions may be /Subtype/TrueType Interrogatories; 1. startxref Attorney, Terms of 0000035367 00000 n Uniform Interrogatories in New Jersey Rule 4 :17-1(b)(2) Cases > > Read More.. Estate, Public Code of Civil Procedure section 2030.290 provides that if responses to interrogatories are not timely, all objec tions are waived, including the work product protection. 18. Planning Pack, Home 39. (i) Reference to any such document by any witness as a basis for establishing any fact upon which reliance is made; or, (ii) Reference to any such document by any expert witness as a basis for his opinion; or, (iii) Introduction into evidence for any purpose; or. 90. 12:235-3.8(d)), and occupational exposure cases (See N.J.A.C. Under N.J.A.C. When the child/children needed school held in the first instance whose assistance was sought? Will the Defendant/Plaintiff rely on expert testimony at time of trial? If you are looking for a lawyer to discuss this with further, please do not hesitate to contact my law firm. 0000004843 00000 n 85. Ms. Burk focuses her practice in the representation of employers, self-insured companies, and insurance carriers in workers compensation defense matters. If the document is commercially printed or published, the name and address of the printer or publisher are required. /Filter/LZWDecode>> Were criminal proceedings ever initiated against the Defendant/Plaintiff by any person other than your spouse? Technology, Power of Has the Defendant/Plaintiff ever been examined or treated by a psychiatrist or psychologist? 24. New Jersey has adopted rules governing practice in Chancery Court 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. 0000000918 00000 n Rule 4:17 - Interrogatories to Parties. Related Forms and Guidance . Does the Defendant/Plaintiff feel that religious training has any importance in the up-bringing of the child/children and, if so, why. A-Z, Form These links are provided for the user's convenience. Thus, if any answer is left blank, it shall be deemed to be none.. information. 47. In the past five (5) years, has anyone maintained a restraining order against you? Law Division, Union County, Docket No. State the names and addresses of all persons known to the Defendant/Plaintiff to possess knowledge of any relevant facts relating to this case. Has the Defendant/Plaintiff ever been arrested? (b) what you generally do/did during such time. The King County Bar Association is not creating an Attorney-Client or Attorney-Attorney relationship by providing this form or other information to you on this site. 40. The Court Rules require that you supply the answers within 60 days after you receive the Interrogatories. In respect to the Plaintiff, compare yourself as to the following categories in terms of being (1) equal, (2) superior, (3) inferior: 15. As between the Plaintiff and yourself, who is in better position to influence the child/children? List all former names and when you were known by those names. of Attorney, Personal 0000000616 00000 n 12. If you're a paid subscriber and still having difficulty, please contact our support desk with your IPv4 address so we can investigate. pretrial discovery proceedings for the Family Division. (e) Discovery shall be completed within 90 days from the date of If you are unsure about your New Jersey Discovery Interrogatories from Plaintiff to Defendant with Production Requests template, contact a legal professional to check it before you decide to send out or file it. Case number. Liens, Real Another example of where special interrogatories would be useful is a situation where there is a dispute over ownership and control of an area. Trust, Living & Resolutions, Corporate TO: Plaintiff ('s) Midland Funding, by and through its attorney of record, Pressler and Pressler, 7 Entin Rd, Parsippany, NJ 07054. State the name and address of the Defendants/Plaintiffs current physician. 0000031860 00000 n 22. I hope these sample workers compensation interrogatories save you time and help you maximize your claim's value. >> 12:235-3.8(g), interrogatories may be allowed in other cases, upon motion, for good cause shown. You must answer each interrogatory separately and fully in writing under oath, unless you object to it. Discovery Interrogatories for Divorce Proceeding for either Plaintiff or Defendant. Necessary cookies are absolutely essential for the website to function properly. Objections may be made to all discovery questions if the questions are not relevant, or likely to lead to the discovery (a) the name, address and telephone number of your employer; (b) whether the position was part-time or full-time; 83. Practitioners should consider filing Motions for Leave to Serve Special Interrogatories in those cases where there is a factual dispute or issue worth investigating. Spanish, Localized 73. 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. Does the Defendant/Plaintiff feel that custody of the child/children with the Plaintiff would be inimical to the childs/childrens health, welfare and general well-being? 6/22. 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 Take the time to make sure your answers are correct and truthful. Has the Defendant/Plaintiff ever struck the child/children within the past 24 months? NJ) %uPkT))awy!SZP4%5;>;xrYr cfTeqiY| 7K&IG#H=U 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. Did you ever attempt to strike the father of the child/children? Your lawyer should advise you that the first round of questions come in the form of Child CustodyInterrogatories. If you are potentially facing a child custody dispute here in New Jersey, my experience as a family law attorney dictates that you should familiarize yourself with the following questions so that you are prepared in case you end of in a New Jersey Family Court. 87. If a legal objection is made with respect to any Interrogatory, you should set forth the specific reason for such objection. Sale, Contract (d) name and address of each institution attended; (e) dates and/or years of education, training, and experience. King County Bar Association 1200 5 th Ave, Suite 700 Seattle, WA 98101 Main (206) 267-7100 Fax (206) 267-7099 34. For example: If your answers to the Interrogatories are different than or inconsistent with your testimony at the time of trial, you will be cross-examined on the inconsistency, and you credibility may be significantly affected. Describe the circumstances leading up to the sale of the Sweet Licks & Bites business. Main (206) 267-7100 In those cases with disputed coverage or policy issues, interrogatories could be served seeking policy documents, cancellation notices, and other documents regarding proper cancellation of coverage. endstream endobj startxref 62. (a) set forth the names and addresses of the child/childrens closet friends? The Court's name. Is the Defendant/Plaintiff a sensitive person? Depositions 8. You should consult a lawyer concerning your specific situation and any specific legal questions you may have. King County Bar Association It also includes requests for production of documents. 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. 0000034244 00000 n r. 1: On January 22, 2021 Plaintiff was operating her vehicle on Maryland Route 152 near its intersection with Reckord Road in Harford County. 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. 34:15-51, which require that a Dependency Claim Petition must be filed within two years of the decedents death. An inquiry is made regarding any new relevant accidents / injuries or claims and any new Awards or settlements. Divorce, Separation Does the Defendant/Plaintiff have any traits or tendencies which you would not like the child/children to emulate? 19. %PDF-1.6 % 0000035626 00000 n 82. Choose a pricing plan and keep on signing up by providing some info. Attach a copy of each such photograph, motion picture or sound recording hereto at our reasonable cost and expense. Sample Plaintiff's Answers to Defendant's Interrogatories. State of New Jersey. >> Did the Defendant/Plaintiff ever attempt to strike the child/children? 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. This field is for validation purposes and should be left unchanged. 7. Has there been any history of suicide or attempted suicide in the Defendants/Plaintiffs extended family? (d) did you tell the child/children where you were going to move? Request for Interrogatories is a common request in the Discovery process of a lawsuit. 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. 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. To do so open the document in Word and go to Tools / Unprotect document. /Type/Font GENERAL OBJECTIONS: Defendant . If they do not give you a response you can send a final request to the plaintiff. Below is a sample set of interrogatories and requests for production of documents that an injured party (the "plaintiff") might send to the defendant in a slip and fall injury lawsuit. This website uses cookies to improve your experience while you navigate through the website. For each of the above persons please . of Business, Corporate Do you now or did you ever spend any time in the company of the child/childrens friends? packages, Easy 12:235-3.8, interrogatories are allowed in the following types of cases without motion (meaning, neither party is required to file a Motion for Leave to Serve Interrogatories with the Court): dependency cases (See N.J.A.C. 16. 89. 0000002399 00000 n hb```t! ,@q(-`fx@_ Ba`$Y4qRd``#eF l Does the Defendant/Plaintiff, or any other member of your household currently smoke or smoked in the last five (5) years? The interrogatories are available in both Word (DOC) and Adobe PDF format. Personal Injury Interrogatories New Jersey, Rule 4:104 - Discovery, NJ Ct. R. 4:104 - Casetext, A4540-16.pdf - Hoagland, Longo, Moran, Dunst & Doukas. Thank you. Attachment(s): PDF Organization: U.S.D.C. Also available is a version of the interrogatories with electronic "forms" that can be filled in. Has the Defendant/Plaintiff been treated for drug use? It also includes requests for production of documents. For example, if you do not have the most recent statement from your pension plan, but can obtain it from your employer, you are obligated to make the inquiry and obtain it from your employer. /Prev 36940 /Parent 1 0 R A-Z, Form Defendant denies the allegations in Paragraph 15 of the Complaint. 0000036691 00000 n 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. (e) did you tell the child/children that you were going to the child/children with you and, if so, why? While this article will focus on spe cific objections, the procedure in responding to discovery is important. Does the Defendant/Plaintiff maintain, or have you in the last five (5) years maintained, a restraining order against any party to this action. %verypdf.com oral questioning, document production and admissions requests are generally Easily find the app in the Play Market and install it for signing your sample answers to interrogatories personal injury attorneys. Agreements, Bill Does the Defendant/Plaintiff have ties to any other state or country? If not, why not? for failing to answer interrogatories and produce documents. /F2 3 0 R Virtually all states have adopted a version of civil procedure rules which include rules dealing with discovery. and R. 4:10-2(d)(2) as to all matters except I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. If so, state as to each position (a) the name, address and telephone number of your employer; (b) is it part-time or full-time (c) the position or title held; (d) how long you have worked at the position; (e) number of days and hours worked and (f) current salary. 9. 80. (f) what was the child/childrens response? Don't waste your requests writing Maura Burk, Esq. (d) if the child/children was injured and, if so, to what extent; (e) if the child/children received medical treatment and, if so, from whom, giving name and address; (g) who was present at each striking, giving names and addresses; (b) why would you not want the child/children to emulate same? (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. "zz}m:e|Sg];#jz:`Me>dq}=[.g98f".p!MU6^Lr6l2%G^oj!DR-^,w\z 5HDe[H. Directive, Power HWrF}+qY 7a05$o3f@FO>|Z qp8 Written questions where you request the other party to admit or deny some relevant fact. Center, Small 67. Double-check that the form youre looking at applies in the state you need it in. 48. 51. (c) full and detailed qualifications training, professional and practical experience, education and degree(s). A procedure designed to allow disclosure of information between Plaintiffs and Defendants. Does the Defendant/Plaintiff have any plans to marry? So, can you refuse to answer interrogatories? The answer not applicable is not acceptable. Second Set - Auto Tort Second of 3 part set of interrogatories for a standard auto tort case. 61 0 obj NEW! 70. By providing information in response to these Interrogatories, Plaintiff does not concede the accuracy of Defendant's definitions, assumptions or allegations. Has the Defendant/Plaintiff in the last five (5) years ever reported acts of alleged domestic violence or injuries observed as to child/children to any law enforcement or medical authority? /L 38289 Learn more about our Diversity & Inclusion initiatives. The interrogatories should seek to obtain information about the contract formation, the parties' conduct, and the damages suffered by the Plaintiff. Personal/Corporate information of opposing party. h]o0/ R)-i$[!.hH"`[w1jhsl$0di&Da!&B1/A!Q track and within 120 days from said date in actions assigned to the standard served by any party as of course pursuant to R. 4:17. Identifying information of witnesses. Click on Buy Now button to access the sign up page. It is extremely important that you call such things to our attention so that we may amend your answers to include the new information. Minutes, Corporate PDF. 25. 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. Handbook, DUI document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); This site uses Akismet to reduce spam. This is not the time to set out your entire case or defense to the other side. Voting, Board Any document containing images (i.e. 17. 23. The interrogatories may include a request, at the propounder's expense, for a copy of any paper. Examples of these would be: List the names, business addresses, dates of employment, and rates of pay regarding all employers, including self-employment, for whom you have worked in the past 10 years. 43. (d) describe in detail the incident you witnessed. Center, Small In California these come on an official court form promulgated by the Judicial Council of California and a party may ask another party to answer any of them by checking the appropriate boxes. 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. 12:235-3.8, interrogatories are allowed in the following types of cases without motion (meaning, neither party is required to file a Motion for Leave to Serve Interrogatories with the Court): dependency cases (See N.J.A.C. New Jersey Discovery Interrogatories from Plaintiff to Defendant with New Jersey Discovery Interrogatories From Plaintiff To Defendant With Production Requests, Living Forward any reports (or resumes or oral reports) received by the Defendant/Plaintiff after these answers to interrogatories were served. _______________________ Attorney ID #___________. 4:17-5 - Objections to Interrogatories. Trust, Living (h) state with specificity the reason(s) you were terminate from and/or quit such job giving the factual basis for same. The method of obtaining documents from the other party relevant to the case such as all documents a party Templates, Name The law requires that you provide not only information which is actually within your possession, but also information which you have the ability to obtain. Tweets by @kingcountybar. N.J.R. are usually recorded by a court reporter, who swears the person to tell Note: This summary is not intended to be an all inclusive summary of discovery law in New Jersey, but does include basic and other information. /Root 62 0 R If you experience any problems with the printing or formatting of this document it is reccommended that you use the PDF version instead of the Word version of the interrogatories. 13. Interrogatories as follows: PRELIMINARY STATEMENT 1. Z~vYk2cI'i1nlYI>W-uiGJj>)u. (b) The 60-day period in R. 4: On appeal from Superior Court of New Jersey,. 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. those relating to the elements that constitute grounds for divorce. 2. /F1 69 0 R Does the Defendant/Plaintiff tolerate the use of drugs in others? 0 Voting, Board A Workers' Guide to Workers' Compensation in New Jersey (legal size paper) wc(g)-338 . allowed. << My firm is ready to help. (e) any problems that occurred during visitation periods. service of the original complaint in actions assigned to the expedited 3. 0000001543 00000 n When practicingfamily lawhere in New Jersey, one of the most fact sensitive areas for an attorney to handle is a child custody case. 4:17-8(b). /H [ 32078 142 ] Contact information & background of expert witnesses. 86. charts, photographs, etc.) Trial by surprise remains a risky endeavor. Agreements, Sale /Type/Page These forms should be used as a guide and should be completed and supplemented as may be appropriate to your case. 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 the Defendant/Plaintiff is not currently working, state as to all positions held for the last 5 years: 84. & Estates, Corporate - /Linearized 1 Change, Waiver If you have additional . Can you perceive any disadvantages to the child/children if custody were given to you? Agreements, Bill of These requests might include: Interrogatories, which are written questions about things that are relevant or important to the case. 75. Who is the child/childrens teacher(s)? 79. These responses and objections are made without prejudice to, and are not a waiver of, Plaintiff's right to rely on other facts or documents at trial. (b) when does the child/children take it; (a) name and address of the party whom you plan to marry; (b) number and age of children, if any, of the party. What are the Defendants/Plaintiffs ties to the State of New Jersey (be specific). 55. In order to add an electronic signature to a sample answers to interrogatories personal injury attorneys, follow the step-by-step instructions below: Log in to your signNow account. The attorneys who sent them to you already have a legal determination that you do owe it. /Font<< Business Packages, Construction (b) the law enforcement or medical authority reported to; (c) the name, address and telephone number of the individual(s) who took your statement and; (d) a detailed account of the statement you provided. The questions are mailed %%EOF If you're using a VPN server, please make sure you're using a US Based VPN Server, or disable it to access our site temporarily. Copyright 2018 All Rights Reserved by New Jersey Judiciary. Amendments, Corporate If you don't have a subscription but need to have New Jersey Discovery Interrogatories from Plaintiff to Defendant with Production Requests, take a look at the guidelines below: Now, submit the file online or print it. 6. (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. 1934 0 obj <>/Filter/FlateDecode/ID[<3AD377403DB9D2478C4A6B7CBAE34CD5>]/Index[1927 24]/Info 1926 0 R/Length 56/Prev 340843/Root 1928 0 R/Size 1951/Type/XRef/W[1 2 1]>>stream /Info 65 0 R 69. For example, a plaintiff may send interrogato 61 12 (b) Uniform Interrogatories in Certain Actions. Records, Annual Defendant filed an answer, separate defenses, and a demand for discovery on December 9, 2015. Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are as essential for the working of basic functionalities of the website. Often the interrogatories served by petitioner asks respondent to identify whether petitioner was an essential worker. Estate, Public These Sample Interrogatories do not change any court requirements. 49. Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. >> track. Your name and address. 50. 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. /Contents 4 0 R Demand is hereby made by the Plaintiff, ____________________________, of the Defendant, ___________________________, to provide answers, under oath or certification to the following Child Custody Interrogatories within the time and in the manner prescribed by the Rules of this Court.