SUPERIOR COURT OF NEW JERSEY

[LAW DIVISION] – [COUNTY]
[CIVIL PART]

[PLAINTIFF NAME],
Plaintiff,

v. Civil Action
Docket No.: [L-____-YY]

[DEFENDANT NAME],
Defendant.

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT [DEFENDANT NAME]

Effective Date: [DATE]
Governing Law: New Jersey Court Rules (state procedural law)
Forum: Superior Court of New Jersey, [County] Vicinage

[// GUIDANCE: Use one interrogatory “set” per party. Do not exceed 25 interrogatories, including sub-parts, without leave of court. N.J. Ct. R. 4:17-1(b)(1).]

TABLE OF CONTENTS

1. Document Header (Caption & Parties)
2. Preliminary Statement & Rule 4:17 Certification
3. General Instructions
4. Definitions
5. Interrogatories (Nos. 1-[25])
6. Verification (Responding Party)
7. Attorney Signature Block
8. Proof of Service

1. PRELIMINARY STATEMENT & RULE 4:17 CERTIFICATION

1.1 These Interrogatories are propounded pursuant to New Jersey Court Rule 4:17 and are to be answered fully and separately, in writing, under oath, and within sixty (60) days after service hereof. N.J. Ct. R. 4:17-4(b).
1.2 The propounding party certifies that the total number of interrogatories, including all discrete sub-parts, does not exceed twenty-five (25). N.J. Ct. R. 4:17-1(b)(1).
1.3 The responding party has a continuing obligation to seasonably amend or supplement its answers in accordance with N.J. Ct. R. 4:17-7.

2. GENERAL INSTRUCTIONS

A. Answer each interrogatory separately and completely.
B. If you object to any interrogatory, state the specific ground(s) and answer so much of the interrogatory as is not objectionable.
C. When asserting a claim of privilege or work-product protection, provide the information required by N.J. Ct. R. 4:10-2(e), including a privilege log sufficient to “enable other parties to assess the claim.”
D. These interrogatories are deemed to be continuing; supplemental answers shall be served promptly upon receipt of new, different, or additional responsive information. N.J. Ct. R. 4:17-7.
E. All terms shall be construed to bring within the scope of the interrogatory any information that might otherwise be construed to be outside its scope.

3. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below:

1. “Action” means the above-captioned lawsuit.
2. “Communication” or “Communications” means any transmission of information by any means, including but not limited to spoken, written, or electronic form.
3. “Document” or “Documents” has the broadest meaning allowable under N.J. Ct. R. 4:10-2, including electronically stored information (“ESI”).
4. “Identify” or “Identification” when used:
   a. With respect to a natural person – state the person’s full name, present or last known address, telephone number, and relationship to the parties.
   b. With respect to an entity – state full legal name, address of principal place of business, and nature of the entity.
   c. With respect to a document – state its date, title, type, author(s), recipient(s), and present custodian or location.
5. “[PLACEHOLDER]” indicates text that must be customized for each matter.

4. INTERROGATORIES

[// GUIDANCE: Replace bracketed text and revise/augment interrogatories to fit the claims and defenses in your case. Keep the total to 25 including sub-parts.]

Interrogatory No. 1 – Parties & Witnesses

Identify every person you believe has knowledge of any facts relevant to the claims or defenses in this Action, and for each such person describe the subject matter of the knowledge you attribute to him or her.

Interrogatory No. 2 – Insurance

State whether you are aware of any insurance agreement under which any insurance business may be liable to satisfy all or part of a judgment that may be entered in this Action or to indemnify or reimburse for payments made to satisfy the judgment, and if so, identify each such agreement.

Interrogatory No. 3 – Contracts & Agreements

Identify and describe all contracts, agreements, or understandings (written or oral) that relate to the subject matter of this Action.

Interrogatory No. 4 – Damages

Describe each category of damages you claim in this Action, including the method of computation for each category and all documents supporting each computation.

Interrogatory No. 5 – Photographs & Recordings

Identify all photographs, videos, audio recordings, or other media that relate to any fact alleged in the pleadings, stating the date created, creator, and present custodian.

Interrogatory No. 6 – Electronic Data Sources

Identify all sources of electronically stored information reasonably likely to contain responsive material, including but not limited to email servers, network drives, cloud repositories, mobile devices, and social media accounts, specifying custodians, date ranges, and data types.

Interrogatory No. 7 – Prior Claims & Litigation

List all lawsuits, claims, arbitrations, or administrative proceedings in the past ten (10) years to which you have been a party that relate to the same or similar subject matter as this Action, stating the caption, docket number, court/agency, and disposition.

Interrogatory No. 8 – Expert Witnesses

Identify each person you expect to call as an expert witness at trial and for each provide the subject matter of testimony, summary of opinions, factual bases, and qualifications.

Interrogatory No. 9 – Basis of Denials

For each allegation of the Complaint that you denied in your Answer, state the factual and legal basis for your denial.

Interrogatory No. 10 – Basis of Affirmative Defenses

For each affirmative defense pleaded in your Answer, state all facts, documents, and witnesses that support that defense.

Interrogatory No. 11 – Persons Preparing Answers

Identify every person who assisted in the preparation of your responses to these Interrogatories, specifying the interrogatories for which each person provided information.

Interrogatory Nos. 12-[25]

[PLACEHOLDER—INSERT ADDITIONAL CASE-SPECIFIC INTERROGATORIES HERE.]

5. VERIFICATION

I, ____, hereby certify and declare under penalty of perjury that I am the [TITLE/POSITION] of [RESPONDING PARTY NAME]; that I have read the foregoing Answers to Interrogatories; that the answers are true and complete to the best of my knowledge, information, and belief; and that I understand my continuing duty to supplement these answers as required by the New Jersey Court Rules.

Date: ___ _____
[NAME], on behalf of [RESPONDING PARTY]

6. ATTORNEY SIGNATURE BLOCK

Respectfully submitted,

[Attorney Name], Esq.
[Law Firm Name]
[Address]
[Telephone] | [Email]
Attorney for [Plaintiff/Defendant] [CLIENT NAME]

Date: _______

7. PROOF OF SERVICE

I certify that on this ___ day of ____, 20__, I caused a true and correct copy of the foregoing Interrogatories to be served upon all counsel of record via [method of service], pursuant to the New Jersey Court Rules.

[Attorney Name], Esq.

[// GUIDANCE:
1. To propound additional interrogatories beyond the 25-question limit, file a motion under R. 4:17-1(b)(i) showing “good cause.”
2. Calendar the 60-day response deadline immediately; unanswered interrogatories may support a motion to compel under R. 4:23-5.
3. Always request a privilege log with the response; failure to provide an adequate log may result in waiver.
4. Consider coordinating ESI protocols early to avoid disputes later in discovery.
]