Mike’s Quick Answer
It depends on the claims and defenses, but often New Jersey discovery requires written questions, documents, medical authorizations, records, expert reports, depositions, and updates so neither side reaches trial without meaningful information. Not every request is automatically proper. A lawyer can object, seek limits, protect confidential material, and explain why a particular record matters.
Discovery Tests the Facts Before Trial
The plaintiff must prove fault, causation, injury, and damages. The defense is allowed to investigate those subjects through interrogatories, document requests, medical examinations, expert discovery, and sworn testimony.
The plaintiff also uses discovery to obtain insurance information, photographs, video, maintenance records, electronic data, policies, witness identities, incident reports, and other evidence controlled by the defense.
Personal Records May Be Relevant Without Being Unlimited
Medical history can matter when the defense claims a condition existed before the accident. Employment and tax records can support lost income. Social-media material may be requested when claimed limitations are disputed.
Relevance does not erase privacy. Scope, dates, confidentiality, privilege, proportionality, and protective orders may be disputed. The lawyer should review what is requested rather than handing over an entire life without analysis.
Accuracy Matters More Than Speed
Discovery answers are often certified as complete and may be compared with records and deposition testimony. Guessing, hiding prior treatment, or giving a careless absolute answer can damage credibility.
Mike can break the requests into manageable steps, identify documents, preserve objections, and prepare accurate responses. The client should ask questions before signing a certification that is unclear or incomplete.
Frequently Asked Questions
Can the defense ask for every medical record I have ever had?
It depends on the injuries, prior history, and wording of the request. Some earlier records may be relevant, but scope and privacy can be challenged when a demand is excessive.
What happens if I remember something after answers are served?
It depends on the stage and importance, but discovery generally has a continuing obligation to correct or supplement material information. Tell the lawyer promptly rather than hoping it never appears.
Sources and Further Reading
Important
This article provides general New Jersey information and is not legal advice. Every matter depends on its facts, policy language, deadlines, and applicable law. Medical questions should be discussed with a licensed physician. Tax questions should be discussed with a qualified tax professional.