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Contention interrogatories attempt to clarify the basis or scope of the opposing party's legal claims.
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.
Notwithstanding the absence of explicit authority under the New Jersey Court Rules, contention interrogatories are frequently used in state court litigation. Their use is implicit in the court rules and the broad scope of discovery.
Rule -2. Interrogatories may, without leave of court, be served upon the plaintiff or answers demanded pursuant to R. -1(b) after commencement of the action and served upon or demanded from any other party with or after service of the summons and complaint upon that party.
If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.
Additional Interrogatories In addition to these mandatory questions, the plaintiff may ask up to ten supplemental interrogatories without leave from the court or more with court permission.