Pleadings and Discovery

Here is what we cover:

• Requests for discovery: How to request and obtain relevant information and documents from the opposing party, and how to respond to requests from the other side, including the scope, timing, and format of the discovery.
• Request for production of medical records: How to request and obtain the medical records of the injured worker, and how to deal with issues such as privacy, consent, and authorization.
• Answers to interrogatories: How to answer and pose written questions that seek information about the facts, opinions, and contentions of the parties, and how to avoid objections and sanctions for incomplete or evasive answers.
• Subpoenas: How to use subpoenas to compel the attendance of witnesses or the production of documents or other evidence, and how to deal with issues such as service, compliance, and quashing.
• Statement of pre-existing conditions: How to prepare and file a statement of pre-existing conditions that may affect the extent of the disability or the causal relationship of the injury, and how to challenge or verify the accuracy of such statements.
• Deposition of infirm testificant: How to request and conduct a deposition of a witness who is unable to attend the trial due to physical or mental incapacity, and how to use the deposition testimony as evidence at the trial.
• Additional discovery methods: How to use other discovery methods that may be appropriate or necessary in certain cases, such as physical or mental examinations, requests for admissions, and expert reports.
• Answering statements: How to prepare and file an answering statement that responds to the allegations and claims of the petition, and how to amend or supplement the answering statement as the case progresses.

This seminar is designed for attorneys, law judges, and risk professionals who want to improve their skills and knowledge in New Jersey workers' compensation law. It will provide you with practical tips, techniques, and examples from experienced and qualified instructors and speakers. It will also give you the opportunity to interact with your peers and discuss your cases and issues.