The Court Rules require plaintiffs provide answers. If answers are not provided your case will be dismissed. Kenneth Vercammen's Law Office is sometimes hired by insurance companies to defend personal injury complaints. The following are some of the Request for documents we request from the plaintiff in a personal injury case.

REQUEST FOR PRODUCTION OF DOCUMENTS - CAR ACCIDENT TO PLAINTIFF

PLEASE TAKE NOTICE that the Plaintiff demands that the defendant produce for inspection and copying pursuant to Rule 4: 18-1, the following documents at the offices of Kenneth A. Vercammen, Esq., 407 Main Street, Metuchen, New Jersey 08840, on ______[30 days from mailing date] at 9:05 a.m.:

RECORDS TO BE PRODUCED

1. All documents relating to the statements of witnesses to the occurrence alleged in your complaint including witnesses who were within sight or hearing of the occurrence or have knowledge from any source as to how it is thought to have occurred. 2. All documents relating to statements of any of the individual parties herein or officers or managing agents of any corporate parties herein. 3. All documents relating to the manner of the occurrence, the events giving rise or leading up to it and the cause thereof, other than any statements of witnesses or parties produced in response to any of the preceding requests. 4. All photographs of the scene of the occurrence. 5. All documents relating to the conditions at the scene of the occurrence (e.g., where appropriate, roadway, surface, weather, construction, traffic signals or signs) at the time of plaintiff's accident. 6. All documents relating to the investigation of the occurrence by or on behalf of any party herein other than those produced in response to any of the preceding requests. 7. All documents relating to the inspection or supervision of activities, if any, at the scene of the occurrence and at the time thereto. 8. All documents relating to complaints to defendant about the premises. 9. All documents in the nature of any expert reports concerning the explanation for or cause of the occurrence. 10. All documents relating to any claims that the Plaintiff sustained financial loss as a result of the occurrence in question, included, but not limited to, W-2 forms and tax returns. 11. All documents relating to the identity of any statute, ordinance or governmental code which it is alleged was violated by any party herein except as already produced in response to any preceding request. 12. Copies of any and all medical reports, bills, summaries, invoices, hospital discharge summaries and any other documents authored by any medical personnel relating to the treatment of the Plaintiff, diagnosis of any injuries and the prognoses of any recovery as a result of this incident. 13. Executed IRS Authorization in the form required by the Federal Government for the five years prior to the date of the incident or certified copies of all IRS tax returns for this period of time. 14. Plaintiff's W-2 forms for the five years prior to the date of the incident. 15. Executed Authorization to obtain personnel records from plaintiff's employer on the date of plaintiff's accident or copies of such personnel records. 16. Executed Authorization to obtain disability records or copies of disability records. 17. Executed Authorization to obtain worker's compensation records or copies of such records. 18. Copies of reports of any and all laboratory tests, CT scans, EEGs, EKGs, X-rays and any other tests taken as a result of the injuries allegedly sustained in this accident. 19. All documents relating or referring to prior litigation plaintiff was involved in prior to or after plaintiff's present litigation, including, but not limited to, pleadings, deposition transcripts, interrogatory answers and expert witness reports.

____________________________________

REQUEST FOR PRODUCTION OF DOCUMENTS - FALL DOWN TO PLAINTIFF- RECORDS TO BE PRODUCED

1. All documents relating to the statements of witnesses to the occurrence alleged in your complaint including witnesses who were within sight or hearing of the occurrence or have knowledge from any source as to how it is thought to have occurred. 2. All documents relating to statements of any of the individual parties herein or officers or managing agents of any corporate parties herein. 3. All documents relating to the manner of the occurrence, the events giving rise or leading up to it and the cause thereof, other than any statements of witnesses or parties produced in response to any of the preceding requests. 4. All photographs of the scene of the occurrence. 5. All documents relating to the conditions at the scene of the occurrence (e.g., where appropriate, roadway, surface, weather, construction, traffic signals or signs) at the time of plaintiff's fall.

6. All documents relating to the investigation of the occurrence by or on behalf of any party herein other than those produced in response to any of the preceding requests. 7. All documents relating to the inspection or supervision of activities, if any, at the scene of the occurrence and at the time thereto. 8. All documents relating to complaints to defendant about the premises. 9. All documents in the nature of any expert reports concerning the explanation for or cause of the occurrence. 10. All documents relating to any claims that the Plaintiff sustained financial loss as a result of the occurrence in question, included, but not limited to, W-2 forms and tax returns. 11. All documents relating to the identity of any statute, ordinance or governmental code which it is alleged was violated by any party herein except as already produced in response to any preceding request. 12. Copies of any and all medical reports, bills, summaries, invoices, hospital discharge summaries and any other documents authored by any medical personnel relating to the treatment of the Plaintiff, diagnosis of any injuries and the prognoses of any recovery as a result of this incident. 13. Executed IRS Authorization in the form required by the Federal Government for the five years prior to the date of the incident or certified copies of all IRS tax returns for this period of time. 14. Plaintiff's W-2 forms for the five years prior to the date of the incident. 15. Executed Authorization to obtain personnel records from plaintiff's employer on the date of plaintiff's fall or copies of such personnel records. 16. Executed Authorization to obtain disability records or copies of disability records. 17. Executed Authorization to obtain worker's compensation records or copies of such records. 18. Copies of reports of any and all laboratory tests, CT scans, EEGs, EKGs, X-rays and any other tests taken as a result of the injuries allegedly sustained in this accident. 19. All documents relating or referring to prior litigation plaintiff was involved in prior to or after plaintiff's present litigation, including, but not limited to, pleadings, deposition transcripts, interrogatory answers and expert witness reports. _____________________

COURT RULE 4:18. DISCOVERY AND INSPECTION OF DOCUMENTS AND PROPERTY, COPIES OF DOCUMENTS

4:18-1. Production of Documents and Things and Entry Upon Land for Inspection and Other Purposes; Pre-Litigation Discovery

(a) Scope. Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on behalf of that party, to inspect and copy any designated documents (including writings, drawings, graphs, charts, photographs, phono-records, and other data compilations from which information can be obtained and translated, if necessary, by the respondent through electronic devices into reasonably usable form), or to inspect and copy, test, or sample any tangible things which constitute or contain matters within the scope of R. 4:10-2 and which are in the possession, custody or control of the party upon whom the request is served; or (2) to permit entry upon designated land or other property in the possession or control of the party upon whom the request is served for the purpose of inspection and measuring, surveying, photographing, testing, or sampling the property or any designated object or operation thereon, within the scope of R. 4:10-2.