The New Jersey Rules of Court provide that [a] party, upon reasonable notice to other parties and all persons affected thereby, may apply for an order compelling discovery. (See Min Wu v. Jafco Foods, Inc., No. GQxE9P8bqo(b ND J`g;% at 517, the depositions were adjourned on two occasions because of defendant Elizabeth Rummel's illness. Plaintiff is not looking for a court order for sanctions or fees. LCV20212099327, 1 WebRule 4:12. The original motion must be filed with the clerk of the court in the county of venue. A party, upon reasonable notice to other parties and all persons affected thereby, may apply for an order compelling discovery as follows: (See Segal v. Lynch (2012) 211 N.J. 230, 256-57. Failure to appear will preclude that person's testimony at trial. 1:5-1 (a) (amended eff 9/1/18). Discovery and calendar motions are considered on the papers unless, on at least 2 days' notice before the return date, the court specifically directs oral argument. It was his view that all of the parties should be deposed together "in the interest of efficiency.". N.J.R. WebMotion for order compelling discovery Motion to remove default Request for production of documents Request for admissions Request for interrogatories Note Some people have trouble opening a file. 127, 131 (App. 37(a)(3) and Local Rule 3.04, Plaintiff moves the Court to compel Defendants to respond to Interrogatories 2 @(%DuI 6v{X+EL. at 401-02,242 A.2d 36; Lindenmuth v. Holden (1996) 296 N.J. Super. 97 N.J. 581 (1984). We have notified your account executive who will contact you shortly. 56 Paterson Street, UNN-L-003942-19 10/19/2021 1:32:51 PM Pg 1 of 56 Trans ID: LCV20212427587 That on March 2, 2017, the attorney representing the Plaintiff requested that all Defendants supply Answers to Interrogatories and responsive documents. Failure of Party to Attend at Own Deposition. N.J.R. WebSAMPLE MOTION TO COMPEL Law Office of Jeffrey J. Downey Serving clients in Virginia, Maryland and Washington D.C. Unless otherwise specified, all allegations of fact are based upon the inspection of the record of this case, conversations with Assistant District Attorneys, independent investigation, the discovery material provided in this case thus far, and/or upon other relevant materials. 42, 51. 1978), aff'd 80 N.J. 343 (1979); U.S. 132gX0cKlVi6b r 11:39:28 AMPgPg 1 of GLO L 001460-2008/23/2021 09/10/2021 01/10/2022 If you cannot open a file, try " right clicking ". 0000002477 00000 n ), While a trial court has wide discretion in deciding the appropriate sanction for a breach of discovery rules, the sanction must be just and reasonable. (See Mauro v. Owens-Corning Fiberglas Corp. (1988) 225 N.J. Super. 0000003743 00000 n Attachment B, Order Compelling Discovery, is a sample form order on a motion to compel. A party, upon reasonable notice to other parties and all persons affected thereby, may apply for an order compelling If the motion is granted, the court shall, after opportunity for hearing, require the party or deponent whose conduct necessitated the motion to pay to the moving party the reasonable expenses incurred in obtaining the order, including attorney's fees, unless the court finds that the opposition to the motion was substantially justified or that other circumstances make an award of expenses unjust. Notes: Be advised: All praecipe and certifications described above shall be made subject to the penalties of 18 Pa.C.S.A. 4:27-1. October 20, 2021 at 195-196. Douglas & Lori Jones 640 0 obj<>stream (c) Award of Expenses of Motion. [DOCUMENT] Roman Christina Vs Ilearn Schools, Inc. [DOCUMENT] Newlin Leighton Vs The Geo Group, Inc. [DOCUMENT] Barlow Tamarria Vs No Credit Auto Sales Llc, [DOCUMENT] Garvin-Keyser Theresa Vs Parking Auth Of City -C. If a deponent fails to answer a question propounded or submitted underR.4:14 or 4:15, or a corporation or other entity fails to make a designation underR.4:142(c) or 4:151, the discovering party may move for an order compelling an answer or designation in accordance with the request. WebMotion to compel. The Order shall set forth the self Too many defense lawyes think discovey is due after a motion compelling it gets granted. N.J.R. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. *7&UXkpfG4V nWK%Uer0Q'g;Z V>f6(7z [^X`0pPQwuUm'.64i"6fAhdexx^[H;mI/[f] 1NMH>!5]af4j> Honorable William J. McGovern III, J.S.C. endobj There is a balancing act with these motions. Rule 4:23-2. We agree with both points. 359, 372.). Thomas D. McCloskey N.J.R. 64, 81. iI{` HNzo`f;H{h_bu/Zra2kt7B4}P%6*'P6rW]^8Gx!bq5L-:QV"z~j{5,$V!Z;%&Ic Csy >QfMDp B:T54vTbs:1}LC#L7+ If the court makes findings of fact and conclusions of law explaining its disposition of the motion, the order will indicate whether the findings and conclusions were written or oral and the date on which they were rendered. The U.S. Supreme Court recently held in Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017) (BMS) that a state court does not have personal jurisdiction over an out-of-state defendant to hear claims brought by an out-of-state plaintiff absent a connection between the forum and the specific claims at issue.In the mass torts Certificate of good faith attempts to resolve discovery dispute. Except as provided in 7:8-9A, if without just excuse or because of failure to give reasonable attention to the matter, an application is made for an adjournment, the court may order the payment of costs and expenses by the party applying for adjournment. State v. Leonardis, 73 N.J. 360, 368 (1977) (Leonardis II); see also Passaic Cty. . N.J.R. Former rule deleted and new R. 4:23-1 adopted July 14, 1972 to be effective September 5, 1972; paragraphs (a) and (c) amended July 13, 1994 to be effective September 1, 1994; paragraph (a) amended July 5, 2000 to be effective September 5, 2000. Generally we decline to interfere with discretionary rulings involving discovery unless it appears that an injustice has been done. 0000002154 00000 n 4:58:12 PM PgPg1 of1 1ofTrans R. 4:23-2(b) provides for the following sanctions: (1) that the matters which are the subject of discovery shall be deemed established for the purpose of the action; (2) refusing to allow the disobedient party to support or oppose designated claims or defenses, or prohibiting him from introducing designated matters in evidence, and (3) striking pleadings or parts thereof, staying further proceedings until the order is obeyed, or dismissing the action or rendering judgment by default. But if you let it go too long, you are going to run into trouble with the scheduling order. 1264 0 obj <>stream Brief in Support of Motion to Compel Discovery. Hon. 1:6-2 (a) (amended eff 9/1/22). Your subscription has successfully been upgraded. Maryland Rule 2-431 and Federal Rule 37 both require certification by the requesting party setting forth the good faith effort that was made to discuss with the opposing attorney the dispute. WebMotion to Compel Depositions in New Jersey What Is a Motion to Compel Depositions? 0000003199 00000 n hbbd```b``~ "[d5d/L~`b {``m0 X\ Y"?&zZ vr"d10128 _= ]7 endobj 1 TransID:ID: den. Don't ask for attorney's fees unless the discovery violations are extreme and especially don't ask for "reasonable expenses" for drafting a template motion like this when the responding party has not provided any response at all. v. Francis (1975)133 N.J. Super. 1 0 obj WebRULE 4:23-1 - Motion for Order Compelling Discovery. N.J.R. ROSE CUNNINGHAM, PLAINTIFF-APPELLANT, Motion for Order Compelling Discovery. Registration is required, but its free and easy! When the motion judge dismissed the complaint she made no factual analysis regarding whether there was bad faith on plaintiff's part, whether lesser sanctions than dismissal "would suffice to erase the prejudice suffered by the non-delinquent party" or whether defendant had been prejudiced at all. WebA sample certification that a party may file in support of a motion to compel discovery in actions pending in the New Jersey Superior Court, Law Division, Civil Part or the 8000 Sagemore Drive Counsel preparing a motion for filing should consult this calendar and select a date listed on the calendar as the "return date for the motion." This Standard Document has integrated drafting notes with important explanations and tips, and includes alternative language based on whether the moving party seeks to compel more specific answers to interrogatories, responses to requests for the production (RFP) of documents (also called document requests or a notice to produce documents), attendance at a deposition, or other discovery. action for wrongful-death damages was quickly followed by Bey Lea's motion to compel arbitration. vM9Ndp*9i) Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-021-6053, https://content.next.westlaw.com/practical-law/document/I53e85ef5b79411e9adfea82903531a62/Certification-Motion-to-Compel-Discovery-NJ?viewType=FullText&transitionType=Default&contextData=(sc.Default), Certification: Motion to Compel Discovery (NJ). A motion to compel against a non-party When taking a deposition on oral examination, the proponent of the question may complete or adjourn the examination before applying for an order. An application for an order to a party may be made On remand, the motion judge should also determine whether defendant Elizabeth Rummel is able to be deposed in view of her present medical condition, and enter the appropriate order. 0000003225 00000 n 0000003058 00000 n Try it out for free. xref ;{ q1QH5>?E{?Zl?im!Z_I[jpA?~K?pyiTDcBxN D&,,}6lGLxV [oG\Pcy7xER%='(^'0 Cumberland/Gloucester/Salem Superior Courts, Somerset/Hunterdon/Warren Superior Courts. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Your alert tracking was successfully added. endstream endobj 654 0 obj<>/W[1 1 1]/Type/XRef/Index[70 568]>>stream I am so grateful that I was lucky to pick Miller & Zois. : MER-L-002124-19 ), The Supreme Court has held that it is especially inappropriate to grant summary judgment when discovery is incomplete[,] in particular, [w]hen 'critical facts are peculiarly within the moving party's knowledge. (See Velantzas v. Colgate-Palmolive Co.,(1988) 109N.J.189, 193; N.J. Anesthesia Assocs. If the hearing is continued, the court may impose sanctions. 134 Franklin Corner Road, Suite 101 A WebA motion to compel asks the court to enforce a request for information relevant to a case. Expenses on Failure to Admit, If a party fails to admit the genuineness of any document or the truth of any matter as requested under R. 4:22, and if the party requesting the admissions thereafter proves the genuineness of the document or the truth of the matter, that party may apply to the court for an order requiring the other party to pay the reasonable expenses incurred in making that proof, including reasonable attorney's fees. ), 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 ofR.4:10-2. (See Id. *16 Before Judges COLEMAN, HAVEY and STERN. This is the most common discovery motion we file. !k')O '=4$!=JnkJfUN-[v^U(u|Qv,% `IHkG?6B@I_K9'w` l. WebAny party to a case may bring a motion. Rule 4:23-3. Web(a) Motion for order compelling discovery Upon reasonable notice to other parties and all persons affected thereby, a party may apply for an order compelling discovery as follows: (1) Appropriate Court. Plaintiff just wants answers so we can proceed with the litigation without delay. A party, upon reasonable notice to other parties and all persons affected thereby, may apply for an order compelling discovery as follows: (a) Motion. Zaccardi v. Becker, 88 N.J. 245, 252 (1982) (Zaccardi II). We noticed that you're using an AdBlocker. CISSY THOMPSON-LYONS, MERCER COUNTYLAW DIVISION Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. 549, 553. ), Furthermore, there must be a substantial showing that [the discovery sought] contain[s] evidence relevant and material to the issue. 1987); Jansson, supra, 198 N.J. Super. November 8, 2021 WebA sample certification that a party may file in support of a motion to compel discovery in actions pending in the New Jersey Superior Court, Law Division, Civil Part or the Chancery Division, General Equity Part. 582, 586 (Law Div. For full print and download access, please subscribe at https://www.trellis.law/. 0000003812 00000 n ROBERT W. ZIMMERMAN/JORDAN L. HOWELL 196, 206,542 A.2d 16; Lindenmuth v. Holden (1996) 296 N.J. Super. If the motion to compel is granted, the court will, after opportunity for hearing, require the party or deponent whose conduct necessitated the motion to pay to the moving party the reasonable expenses incurred in obtaining the order, including attorney's fees, unless the court finds that the opposition to the motion was substantially justified WebPlaintiff Fact Sheet Instructions: Pursuant to this Courts Case Management Order No. Discovery rules are designed to further "the public policies of expeditious handling of cases, avoiding stale evidence, and providing uniformity, predictability and security in the conduct of litigation." 0000001343 00000 n JEDS EF-953478, ORDER TO COMPEL DISCOVERY-Granted by Judge FRIEDMAN, SANDER, D re: MOTION , ORDER TO COMPEL DISCOVERY-Granted by Judge CHELL, TIMOTHY, W re: MOTION TO, Ryan Michael Vs Mj Builders & Devel Group Llc, Motion to Compel Further Responses to Interrogatories, Motion for SanctionsFailure to Comply with Discovery, [DOCUMENT] Cit Finance Llc Vs 17240 Hall, Llc. Richard J. Heleniak, CHERRY HILL, NJ 08003 However, defendant Elizabeth Rummel suffered a stroke and could not attend. I also understand that Miller & Zois works with multiple law firms on these claims and that I may be contacted by an affiliated law firm working with Miller & Zois on these lawsuits. N.J.R. Last. ), 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 date 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 ofR.4:10-2 and which are in the possession, custody or control of the party upon whom the request is served; (See Lindenmuth v. Holden (1996) 296 N.J. Super. A-4788-11T4, at *9 (App. The Motion Calendar can be found at: http://www.judiciary.state.nj.us/calendars/motion_1.htm. WebNew Jersey Rules of Court New Jersey Rules of Court. Too many defense lawyes think x} xEWsff2`&9LN1 j G&U/]5hVw=QP(x ?]~;V}UUuuUL'!FD O=jCv7Qm+*sLX,X?jYovb,DL'Y7[w8(fq=+bJ?/ wvyMGvoj|W Kl'0Hkn9jhZ"P$Q YyyPQ+fUrnO5iEcer PYD~Y\Tm`[yt-tcbo%tYx Proc. A copy of these letters are attached as Exhibits B and C. As of the present date, the Plaintiff has not yet received executed Answers to Interrogatories or a Response to the Request for Production of Documents from the Defendants. The Rules Governing the Courts of the State of New Jersey may be cited two ways, as "N.J. Court Rules, 1969" or more commonly, for example "R. 1:1-3". Here, the "local rule" clearly undermines the Supreme Court's exclusive domain as well as the public policies of providing "uniformity, predictability and security in the conduct of litigation" throughout the State. Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! Feb. 25, 2020). Exhibits to a pleading or paper may be incorporated by reference in a different part of the same pleading, or in another pleading or paper. Probation Officers' Ass'n v. Cty. We must therefore assume, as do the parties, that the order of dismissal was entered, at least in part, because of the motion judge's adherence to the "local rule." Docket No: UNN-L-3942-19. Morris County Civil Divisio, BUR L 000076-21 09/15/2021 Pg 1 of 1 Trans ID: LCV20212147633 As with any form, these forms cannot appropriately be applied to a specific transaction without first being substantively revised; therefore, it should not be used as a replacement for professional legal, tax, financial, and technical advice in any transaction. In most jurisdictions, the opposing party has 30 days to provide the requested information. (c) Motion to Compel. 5 If the motion is granted in part and denied in part, the court may apportion the reasonable expenses incurred in relation to the motion among the parties and persons in a just manner. The motion judge granted the motion, observing that R. 4:23-2(b)(3) authorized *18 the dismissal and that there is no requirement under the rules "that such deposition be scheduled pursuant to Court order.". Here, dismissal of the complaint, predicated at least in part on the "local rule," was an abuse of discretion. Web: : : : : : : : : : : CIVIL ACTION NO. N.J.R. UtjrZ^Kkh. VI, II, par. Respectfully submitted,Miller & Zois, LLC, Ronald V. Miller, Jr.1 South St, #2450Baltimore, MD 21202(410)779-4600(410)760-8922 (Fax)Attorney for the Plaintiff. Below is a sample motion to compel discovery. 1960); Gargano v. Venezio, 38 N.J. Super. 1:2-4 (a) (amended eff 9/1/18). Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. 0000003589 00000 n 329, 332 (App.Div. For the purposes of this subdivision an evasive or incomplete answer is to be treated as a failure to answer. International Sales(Includes Middle East), Business Insight Solutions Partner Portal, Corporate InfoPro (Corporate Information Professionals), InfoPro (Legal Information Professionals). October 19, 2021 If the motion to compel is granted, the court will, after opportunity for hearing, require the party or deponent whose conduct necessitated the motion to pay to the N.J.R. If a party or an officer, director, or managing agent of a party or a person designated under R. 4:14-2(c) or 4:15-1 to testify on behalf of a party fails to appear before the officer within this State who is to take his deposition, after being served with a proper notice, the court in which the action is pending on motion may make such orders in regard to the failure as are just, and among others it may take any action authorized under paragraphs (1), (2) and (3) of R. 4:23-2(b). The Zaccardi, supra, 88 N.J. at 252. 240, 279 (App. Rule 1:6 - Motions and Briefs in the Trial Courts. Props., LLC v. McCusker, No. I understand that submitting this form does not create an attorney-client relationship. We therefore reverse and remand for further proceedings. Gregory R. Sellers Moving papers must be filed and personally served at least sixteen (16) days before the selected return date. Background After commencement of the action, any party may take the testimony of any Motion to Compel Discovery Discovery is the process by which the parties to a legal action request and obtain information and evidence from the other parties. A motion to compel against a non-party 0000001915 00000 n v. Blackburn, No. 638 17 SALTZ MONGELUZZI & BENDESKY P.C. Defendants thereupon moved to dismiss the complaint. 1 of Superior Court of New Jersey Bergen County. <<95ad678d1b862b4e9402f548802fc4f2>]>> MANDY GLENN- PlaintiffvSTEVEN KENNEDY, et al. Motions must be typed on 28-line pleading paper and follow a PHONE: (215) 399-9255 In practice, however, the court often fixes the time to make discovery in orders granting motions to compel irrespective of the basis for the motion. (a) Motion for Order Compelling Discovery. We do not retain jurisdiction. Elizabeth, NJ 07207 How Maryland Personal Injury Lawyers Should Deal with Motions to Compel Discovery. Marlton, NJ 08053 MID-L-005163-18 10/20/2021 2:50:55 PM Pg 1 of 1 Trans ID: LCV20212441516 Union County Courthouse Further, plaintiff was ready and able at all times to attend the deposition. 5. NEW RULE AMENDMENTS EFFECTIVE APRIL 25, 2022, Moving Papers-Personal Service Sixteen (16) Days' Notice. Prior to moving to dismiss pursuant to subparagraph (a)(1) of this rule, a party may move for an order compelling discovery demanded To view this free sample motion to compel discovery, click the link below. endstream endobj 649 0 obj[3[250 333]36[722]38[722 722 667 611 778 778 389 500 778 667 944 722 778]53[722 556 667 722 722 1000]60[722]177[500]179[500 500]182[333]] endobj 650 0 obj<> endobj 651 0 obj<>stream 1:4-5. FAX (856) 751-0868 If the delinquent party fails to comply by this date, the aggrieved party may file a motion for dismissal or suppression. VIA E-COURTS Not a Lexis+ subscriber? <> A motion to compel disclosure or discovery pursuant to Rule 37 must be brought in the court where the action is pending. Your recipients will receive an email with this envelope shortly and Here, adherence to the "local rule" was such an injustice. If a party has chosen to file a motion to compel where there has been complete failure to make written discovery or submit to examinations, any order granting that motion will specify the date by which compliance is required. 1980). WebSince there are no pre-printed Judicial Council forms for motions to compel responses, you must draft them yourself. ), Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense of any other party, including the existence, description, nature, custody, condition and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter. (See Korostynski v. Gaming Enforcement (1993) 266 N.J. Super. . Make your practice more effective and efficient with Casetexts legal research suite. 114, 120 (App.Div. A-2539-18T2, at *18 (App. 7 dated July 1, 2015, each plaintiff shall serve his or her completed Plaintiff Fact Sheet on VIA MAIL: Get free summaries of new New Jersey Superior Court, Appellate Division - Published Opinions opinions delivered to your inbox! Plaintiff's counsel refused to produce plaintiff at the depositions. xV]k@|?>uw`Jj-SK~BW0=,moVyxApt5y[x_YGm[#l~} Direct Dial: (215) 400-2845 N.J.R. %PDF-1.6 % 1985). Defendant seeks for the Plaintiff to pay his costs association with this Motion pursuant to O.C.G.A. A-2772-15T1, at *10-11 (App. 1:6-2 (c) (amended eff 9/1/22). P3Dq(\,C2X00(~zqdW(P2 e|:K4 0p M rqvR AJAH/|\UsMl p=Mu'P]S Y +]H yb68] j00wt4| b b8 @JPH"U5HHB AFA g! ), In the exercise of that discretion, the trial court can suspend the impositions of sanctions (1) where there is an absence of a design to mislead; (2) where there is an absence of the element of surprise if the evidence is admitted; and (3) where there is an absence of prejudice which would result from the admission of the evidence. (SeeBrown v. Mortimer, supra, 100 N.J. Super. 0000000016 00000 n The Plaintiff, Mandy Glenn, by her attorney, Ronald V. Miller, Jr., moves pursuant to Maryland Rule of Procedure 2-432 for an Order compelling the Defendants, Steven Kennedy, Michael Davis, and Erie Insurance Exchange, to promptly produce all outstanding discovery, and in support, states as follows: WHEREFORE, the Plaintiff moves for an Order compelling the Defendants to produce complete and executed Answers to Interrogatories and the required documents within the next 15 days. Ms. Leave of court to file a brief may be applied for ex parte. Use the button on your mouse that you do not normally use and pick ' Save link as.. Dismissal of a complaint, of course, is not the sole remedy when a plaintiff violates a discovery rule. ~?O_"uIhx;mzBzv6Nz*=%FQ77i0ZIJo9;. When making a motion to compel, the moving party is asking the judge to use the power of the court to essentially force another party to do something that he or she has so far refused to do. The motion was denied because of a "local rule" that the appropriate motion when a party fails to attend a deposition is for dismissal of the complaint or suppression of the answer, rather than to fix a date certain for the deposition. 514, 517 (App.Div. Rule 4:23-6. The state judiciary website provides a guide to all citation forms used in New Jersey. This rule-making authority "has also been widely recognized as falling within court's inherent powers." In such circumstances, the court has the obligation to resolve the discovery dispute. (See Brugaletta v. Garcia (2018) 234 N.J. 225, 249-50. 8 will be able to access it on trellis. A motion to compel disclosure or discovery pursuant to Rule 37 must be brought in the court where the action is pending. R.4:17-5(b).When a responding party declines to turn over requested trailer Feb. 25, 2022). M. DANIEL CANTOR, ESQUIRE ), It is well settled that Rule4:17-1(4) provides, [e]xcept as otherwise provided [e.g., where a claim of privilege is made or where the information is the subject of a protective order,] every question propounded by a uniform interrogatory must be answered unless the court has otherwise ordered.(See Herrick v. Wilson, No. Plaintiffs, Civil No. If the motion is denied, the court shall, after opportunity for hearing, require the moving party to pay to the party opposing the motion the reasonable expenses incurred in opposing the motion, including attorney's fees, unless the court finds that the making of the motion was substantially justified or that other circumstances make an award of expenses unjust. The form of order must indicate whether the motion was opposed or unopposed. New Jersey Court Rule 1:6 governs the procedure for filing motions in the Superior Court of New Jersey Law Division, and Chancery Division, General Equity. The Honorable James Den Uyl Individual courses and subscriptions available. 4904 regarding unsworn falsifications to authorities. 4 0 obj %%EOF For the reasons set forth in the materials filed in support of this Motion, good 0000001465 00000 n 3. 11 Webshall assign the Discovery Motion a control number. Irene M. McLafferty , MRS-L-002163-19 09/15/2021 03:34:22 PM Pg 1 of 27 Trans ID: LCV20212143785 A party, upon reasonable notice to other parties and all persons affected thereby, may apply for an order compelling discovery as follows: If the motion is denied, the court shall, after opportunity for hearing, require the moving party to pay to the party opposing the motion the reasonable expenses incurred in opposing the motion, including attorney's fees, unless the court finds that the making of the motion was substantially justified or that other circumstances make an award of expenses unjust. Such liberal construction allows the court to compel a party to produce all relevant, unprivileged information which may lead to the discovery of relevant evidence concerning the respective positions of both plaintiff and defendant. (See Korostynski v. Gaming Enforcement (1993) 266 N.J. Super.
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