Interrogatory Questions and Discovery The Answer is followed by a request for written interrogatories. These are questions that must be answered by each party. In Personal Injury cases the plaintiff's attorney will demand the Defendant provide Certified Answers to Uniform Interrogatories Form C, plus C(1) Interrogatories in Auto cases ( or C (2) if this is a non- Auto case), to be answered within 60 days pursuant to Rule 4:17-1 et seq. The Court Rules require plaintiffs provide answers. If answers are not provided your case will be dismissed. You must answer each and every question as detailed as possible. Do not answer any of the questions with, "see doctor's report" or "see bills." We strongly recommend you visit the accident site if possible to refresh your recollection as to distances and buildings nearby. Your attorney will later type up your answers and mail a copy back to you for your records.

Request for Production of Documents Kenneth Vercammen's office will also demand a Request for Production of Documents pursuant R. 4:18-1, which includes a Demand for Discovery of Insurance. Generally, written interrogatories are followed by the taking of depositions, which is recorded testimony given under oath by any person the opposition wishes to question. In the event you are deposed during the course of this action, you will receive detailed instructions as to procedure and will be requested to watch a videotape. After taking depositions, the case will be set down for an Arbitration. If the parties do not settle after the Arbitration, the case will be given a trial call date. Altogether, these procedures may take from twelve months to several years, and your patience may be sorely tried during this time. However, it has been our experience that clients who are forewarned have a much higher tolerance level for the slowly turning wheels of justice. Court Rule 4:22-1. sets forth the Rule on Request for Admission: A party may serve upon any other party a written request for the admission, for purposes of the pending action only, of the truth of any matters of fact within the scope of R. 4:10-2 set forth in the request, including the genuineness of any documents described in the request. Copies of the documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying. The request may, without leave of court, be served upon the plaintiff after commencement of the action and upon any other party with or after service of the summons and complaint upon that party. Each matter of which an admission is requested shall be separately set forth. The matter is admitted unless, within 30 days after service of the request, or within such shorter or longer time as the court may allow, the party to whom the request is directed serves upon the party requesting the admission a written answer or objection addressed to the matter, signed by the party or by the party's attorney. If objection is made, the reasons therefor shall be stated. The answer shall specifically deny the matter or set forth in detail the reasons why the answering party cannot truthfully admit or deny the matter. A denial shall fairly meet the substance of the requested admission, and when good faith requires that a party qualify the answer or deny only a part of the matter of which an admission is requested, the party shall specify so much of it as is true and qualify or deny the remainder. An answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless stating that a reasonable inquiry was made and that the information known or readily obtainable is insufficient to enable an admission or denial. A party who considers that a matter of which an admission has been requested presents a genuine issue for trial, may not, on that ground alone, object to the request but may, subject to the provisions of R. 4:23-3, deny the matter or set forth reasons for not being able to admit or deny. When we serve the Request for Admissions, the individual statements should be written so that the opposing side must Answer "admit" after each one.

Superior Court Civil Arbitration All civil lawsuits are required to participate in a Civil Arbitration at the County Courthouse or in a Mediation. In Middlesex County cases, these are held at the Middlesex County Courthouse Building, 1st Floor, 1 John F. Kennedy Square at Bayard Street, New Brunswick, New Jersey. The Arbitration is held before an attorney selected by the Assignment Judge who will read medical reports and statements submitted by the parties, then listen to testimony from the parties for approximately 15 minutes. The Arbitrator will make a decision as to who is responsible and whether damages should be awarded. Most Personal Injury attorney mail a draft of the Arbitration Statement to their clients ahead of time. We recommend clients notify our office immediately in writing with any changes in the Arbitration Statement. We suggest you visit the accident site during the week prior to Arbitration, and call all of your doctors to confirm all bills are paid. We provide a copy of your Answers to Interrogatories to our clients. Personal injury clients should carefully review the answers to interrogatories before the Arbitration. You should be fully familiar with the information which was supplied by way of answers to interrogatories because many of the Arbitration questions will involve the same information. If you cannot locate your copy of the Answers to the Interrogatories, please call your attorney's office and they should forward to you another copy of the Answers to the Interrogatories. You must be present in court and prepared to proceed at that time. You should bring all of your papers in connection with your case to Court. Please call your attorney's secretary approximately 24 hours before this hearing to confirm that the court has not adjourned your hearing. CONCLUSION

If a lawsuit is filed, immediately schedule a consultation with an attorney. Our office represents parties in Civil Litigation cases. If facing a lawsuit, immediately schedule an appointment with a civil attorney. Don't rely on a real estate attorney, public defender or a family member who took a law class in school. When your life and business is on the line, hire the best attorney available.

KENNETH VERCAMMEN & ASSOCIATES, PC ATTORNEY AT LAW

2053 Woodbridge Ave. Edison, NJ 08817 (Phone) 732-572-0500 (Fax) 732-572-0030

TRIAL AND LITIGATION EXPERIENCE

In his private practice, he has devoted a substantial portion of his professional time to the preparation and trial of litigated matters. He appears in Courts throughout New Jersey several times each week on many personal injury matters, Criminal and Municipal/ traffic Court trials, Probate hearings, and contested administrative law hearings.

Mr. Vercammen served as the Prosecutor for the Township of Cranbury, Middlesex County and was involved in trials on a weekly basis. He also argued all pre-trial motions and post-trial applications on behalf of the State of New Jersey.

He has also served as a Special Acting Prosecutor in Woodbridge, Perth Amboy, Hightstown, Carteret, East Brunswick, Jamesburg, South Brunswick, South River and South Plainfield for conflict cases. Since 1989, he has personally handled hundreds of criminal and motor vehicle matters as a Prosecutor and now as defense counsel and has had substantial success.

Previously, Mr. Vercammen was Public Defender for the Township of Edison and Borough of Metuchen and a Designated Counsel for the Middlesex County Public Defender's Office. He represented indigent individuals facing consequences of magnitude. He was in Court trying cases and making motions in difficult criminal and DWI matters. Every case he personally handled and prepared.

His resume sets forth the numerous bar associations and activities which demonstrate his commitment to the legal profession and providing quality representation to clients.

Since 1985, his primary concentration has been on litigation matters. Mr. Vercammen gained other legal experiences as the Confidential Law Clerk to the Court of Appeals of Maryland (Supreme Court) with the Delaware County, PA District Attorney Office handling Probable Cause Hearings, Middlesex County Probation Department as a Probation Officer, and an Executive Assistant to Scranton District Magistrate, Thomas Hart, in Scranton, PA.