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Kenneth Vercammen & Associates
A Law Office with Experienced Attorneys for Your New Jersey Legal Needs

2053 Woodbridge Ave.
Edison NJ 08817
732-572-0500
1-800-655-2977

Personal Injury and Criminal
on Weekends 732-261-4005

Princeton Area
68 South Main St.
Cranbury, NJ 08512
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Documents an Injured Person Can Be Required to Provide to the Defendants Attorney

By Kenneth Vercammen An injured person and their attorney must answer Court Rule Interrogatory Questions Form A, plus supplemental questions propounded by the attorney for the defendant. The injured person is also required to provide photocopies of documents

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., 2053 Woodbridge Avenue, Edison, New Jersey 08817, 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 plaintiffs 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. Plaintiffs W-2 forms for the five years prior to the date of the incident. 15. Executed Authorization to obtain personnel records from plaintiffs employer on the date of plaintiffs accident or copies of such personnel records. 16. Executed Authorization to obtain disability records or copies of disability records. 17. Executed Authorization to obtain workers 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 plaintiffs 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 plaintiffs 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. Plaintiffs W-2 forms for the five years prior to the date of the incident. 15. Executed Authorization to obtain personnel records from plaintiffs employer on the date of plaintiffs fall or copies of such personnel records. 16. Executed Authorization to obtain disability records or copies of disability records. 17. Executed Authorization to obtain workers 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 plaintiffs 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.

(b) Procedure. 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. A copy of the request shall also be simultaneously served on all other parties to the action. The request shall set forth the items to be inspected either by individual item or by category, and describe each item and category with reasonable particularity. The request shall specify a reasonable time, place, and manner of making the inspection and performing the related acts. The party upon whom the request is served shall serve a written response within 35 days after the service of the request, except that a defendant may serve a response within 35 days after service of the summons and complaint upon that defendant. On motion, the court may allow a shorter or longer time. The written response, without documentation annexed but which shall be made available to all parties on request, shall be served by the party to whom the request was made upon all other parties to the action. The response shall state, with respect to each item or category, that inspection and related activities will be permitted as requested, unless the request is objected to, in which event the reasons for objection shall be stated. If objection is made to part of an item or category, the part shall be specified. A party who produces documents for inspection shall produce them as they are kept in the usual course of business or shall organize and label them to correspond with the categories in the request. The party submitting the request may move for an order of dismissal or suppression pursuant to R. 4:23-5 with respect to any objection to or other failure to respond to the request or any part thereof or any failure to permit inspection as requested. (c) Persons not Parties. This rule does not preclude an independent action against a person not a party for production of documents and things and permission to enter upon land. Pre-litigation discovery within the scope of this rule may also be sought by petition pursuant to R. 4:11-1.

   
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Since 1985, KENNETH VERCAMMEN has worked as a personal injury attorney, working for injury victims and their families. By taking a hard-hitting, aggressive approach toward the insurance companies, KENNETH VERCAMMEN and our co-counsel have consistently obtained outstanding results for many injured clients over the years I am proud to have worked on cases in various capacities, small and large. While obviously prior results cannot guarantee the outcome of future cases, I can guarantee that you case will receive the same degree of dedication and hard work that went into each of these prior cases.

In direct contrast to the hard-hitting approach we take toward the insurance companies is the soft approach we take toward our clients. I am proud of my compassionate staff as I am of the outstanding financial results they have achieved. For many years, I have watched them treat our clients with patience, dignity and respect. I would have it no other way.

Many years ago, I attended a seminar sponsored by the American Bar Association on Law Practice Management. This was to help insure that each of our clients is always treated like a person -- not a file! We recognize that you are innocent victims and that you have placed your trust in us. Please understand that we understand what you are going through. Feel comforted that we are here to help you.

If you retain KENNETH VERCAMMEN to represent you, we will give you the same advice we give each of our clients -- concentrate on your life, you family and your health. We will take care of everything else. Leave all of the work and worry about your legal rights to us. Trust us. Believe in us. Have faith in us as your attorneys. Understand that we will always to do what we believe is best for you and your case. Helping you is our job. In fact, it is our only job -- guiding injury victims like you through one of the most difficult times of your lives, with care and concern -- while fighting aggressively to the limits of the law to obtain compensation and justice for each of you!

Print our Personal Injury Questionnaire on our Website, Fill it out and Fax back, so we can determine if we can help you obtain an injury settlement. We would welcome an opportunity to prove to you what we have proven to thousands of injured clients -- that you can feel comfortable and secure in the fact that KENNETH VERCAMMEN - Trial Attorney We Fight To Win.

When you have been injured in an accident or collision, you are worried about who is going to pay your medical bills, lost wages, and other damages. The last thing you want is to be taken advantage of by an insurance company. If you dont protect your rights, you may not be able to make a claim.

Insurance companies have attorneys and adjusters whose goal is to pay you as little as they can. You need a New Jersey personal injury lawyer to fight for you. I am dedicated to helping your recover as much money as possible under the law.

You need an attorney who will work hard to protect your rights, maximize your insurance settlement and minimize the hassles of dealing with the insurance companies. You need an experienced and aggressive New Jersey trial lawyer with PROVEN RESULTS who will fight for you. Having an experienced personal injury lawyer can make the difference between getting what you deserve and getting nothing.

Without the threat of a lawyer who is willing to go to trial and seek a big jury verdict, why would an insurance company pay you what your claim is really worth? Lawsuits can be expensive, and many people do not have the money to pursue their claim. In every case, I advance all costs associated with pursuing your case and I do not ask you for a penny until we recover from the other side.

I am an experienced aggressive trial lawyer and a 3rd degree Black Belt. I am not afraid to take your case to trial if that is what it takes to maximize the amount of money your recover for your personal injury. I offer one-on-one service, and I will not hand your case off to an inexperienced lawyer or a paralegal.

Reduce the stress of making a claim.

Personal injury accidents can turn your life upside down. Making a personal injury claim can be difficult and time consuming. Once I take your case, you can stop worrying about dealing with the insurance companies and focus on recovering from your injuries. I take care of all of the paperwork, phone calls, and negotiations, so you can get on with your life.

p.s. For those clients who are afraid or reluctant to go to Court, KENNETH VERCAMMEN also offers a special -- For Settlement Only -- program. This means that if we are unable to settle with the insurance company, we will not go any further -- unless you want us to. You have my personal assurance that there will be absolutely no pressure and no obligation.

We handle personal injury cases on a contingency fee basis.

This means: YOU DONT OWE ME A LEGAL FEE UNLESS I RECOVER MONEY FOR YOU.

Call our office to schedule a "confidential" appointment 732-572-0500

Kenneth A. Vercammen is the Managing Attorney at Kenneth Vercammen & Associates in Edison, NJ. He is a New Jersey trial attorney has devoted a substantial portion of his professional time to the preparation and trial of litigated matters. He has appeared in Courts throughout New Jersey each week on personal injury matters, Criminal /Municipal Court trials, and contested Probate hearings.

Mr. Vercammen has published over 125 legal articles in national and New Jersey publications on criminal, elder law, probate and litigation topics. He is a highly regarded lecturer on litigation issues for the American Bar Association, NJ ICLE, New Jersey State Bar Association and Middlesex County Bar Association. His articles have been published in noted publications included New Jersey Law Journal, ABA Law Practice Management Magazine, and New Jersey Lawyer. He is the Editor in Chief of the American Bar Association Tort and Insurance Committee Newsletter.

Admitted In NJ, US Supreme Court and Federal District Court.

Contact the Law Office of
Kenneth Vercammen & Associates, P.C.
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The Law Office cannot provide legal advice or answer legal questions over the phone or by email. Please call the Law office and schedule a confidential "in office" consultation.

.Ken Vercammen articles

Ken Vercammens Resume
Directions to Ken Vercammen and Associates




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