Interrogatories
(NJ)

Summary

These Interrogatories are for discovery between parties in civil actions in New Jersey Superior Court. This template includes the components of a complete set of interrogatories, including a caption, definitions, instructions, and a certification. This template includes practical guidance, drafting notes, and alternate and optional clauses. N.J. Ct. R. 4:17-1 governs interrogatories. The request can be sent to a plaintiff after the commencement of the suit or upon any other party with or after the service of the summons and complaint, with a copy to all other parties. The recipient of the interrogatories is to answer within 60 days of receipt. N.J. Ct. R. 4:14-4(b). Generally, there is no limit on the number of interrogatories you may propound on your adversary. However, in cases involving personal injury, property damage to automobiles, product liability cases (aside from pharmaceutical and toxic tort cases) and medical malpractice cases, interrogatories are limited to those in Forms A, B, and C in Appendix II of the New Jersey Court Rules. In these cases, each party is allowed to propound an additional 10 supplemental interrogatories without subparts to other parties. If you want to propound other additional interrogatories, you will need the court's permission. The form interrogatories are deemed served upon a defendant with the complaint and summons. The defendant has 60 days to answer the form interrogatories. The form interrogatories are deemed served upon the plaintiff with the service of defendant's answer. The plaintiff has 30 days to answer the form interrogatories. When drafting interrogatories, keep the following in mind: • N.J. Ct. R. 4:10-1, et seq. (N.J. Ct. R. 5:5-1 in Family Part) governs all aspects of discovery in civil litigation, including interrogatories. Read it before drafting interrogatories to understand both the letter and the spirit of the discovery process, including its scope and limitations. • Start with general questions and then move to specific questions, beginning with an interrogatory requesting the identity of the person answering. • Be sure interrogatories are comprehensible to avoid an objection from the answering party. • Be sure interrogatories do not request privileged or irrelevant information. Note that they may seek inadmissible information as long as it is reasonably calculated to lead to the discovery of admissible evidence. See N.J. Ct. R. R. 4:10-2(a). • Proofread comprehensively to be sure dates, times, places, identities, and other facts set out in your interrogatories are correct. • Serve interrogatories early and keep an eye on your deadlines. The Superior Court assigns a Track number to a case limiting the time in which to conduct discovery. For more information on the tracks, see Application to Change Track Assignment (NJ). For a full listing of key content covering fundamental civil litigation tasks throughout a New Jersey state court litigation lifecycle, see Civil Litigation Fundamentals Resource Kit (NJ). For more information on interrogatories see Interrogatories: Drafting and Serving Interrogatories (NJ) and Interrogatories: Responding to Interrogatories (NJ). For a related checklist, see Interrogatories: Responding to Interrogatories Checklist (NJ). For a template, see Objections and Responses to Interrogatories (NJ). For general information on discovery, see Scope of Discovery (NJ).