This form for use in litigation against an insurance company for bad faith breach of contract. Adapt this model form to fit your needs and specific law. Not recommended for use by non-attorney.
New Jersey Complaint For Failure Of Insurer To pay Benefits - Jury Trial Demand
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How to fill out Complaint For Failure Of Insurer To Pay Benefits - Jury Trial Demand?
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(a) Demand; Time; Manner. Except as otherwise provided by R. -5 (summary actions), any party may demand a trial by jury of any issue triable of right by a jury by serving upon the other parties a demand therefor in writing not later than 10 days after the service of the last pleading directed to such issue.
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, copy, test, or sample any designated documents (including writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored ...
DEFINING ?POSSESSION, CUSTODY, OR CONTROL? Court Rule -1(a) permits a request for any documents within the opposing party's ?possession, custody or control.? [R. -1(a).]
The party on 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 50 days after service of the summons and complaint on that defendant. On motion, the court may allow a shorter or longer time.
When any document or paper is referred to in a pleading but is neither annexed thereto nor recited verbatim therein, a copy thereof shall be served on the adverse party within 5 days after service of his written demand therefor.
. A party seeking any affirmative relief may, at any time after the expiration of 35 days from the service of the pleading claiming such relief, move for a summary judgment or order on all or any part thereof or as to any defense.
8, when a party is served with a frivolous complaint, counterclaim, motion or other similar ?paper? (as such filings are described in the Rules of Court), the party must give the opposing attorney and party an opportunity to correct the error. See, e.g., Venner v. Allstate, 306 N.J. Super.