Objections and Responses to Interrogatories
(NJ)

Summary

This Objections and Responses to Interrogatories template may be used when responding to Interrogatories served by an adverse party in a New Jersey Superior Court. You may use these objections as the complete answer to a set of interrogatories or in conjunction with your client's answer. It contains practical guidance and drafting notes. Interrogatories are governed by N.J. Ct. R. 4:17-1. The requests 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 Rules Governing the Courts of the State of New Jersey. In these cases, each party is allowed to propound an additional 10 supplemental interrogatories without subparts to other parties. If you want to propound 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 interrogatories. The interrogatories are deemed served upon the plaintiff with the service of defendant's answer. The plaintiff has 30 days to answer. 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 responding to interrogatories, see Interrogatories: Responding to Interrogatories (NJ). For information on drafting and serving interrogatories, see Interrogatories: Drafting and Serving Interrogatories (NJ). For a related template, see Interrogatories (NJ).