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4:18-1-Production of Documents, Electronically Stored Information, and Things and Entry Upon Land for Inspection and Other Purposes; Pre-Litigation Discovery 4:18-1, 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, copy, test, or sample any designated documents (including writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information, and any other data or data compilations stored in any medium from which information can be obtained and translated, if necessary, by the respondent into reasonably usable form), or to inspect, copy, test, or sample any designated tangible things that constitute or contain matters within the scope of R. 4:10-2 and that are in the possession, custody or control of the party on whom the request is served; or (2) to permit entry upon designated land or other property in the possession or control of the party on 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. , Procedure; Continuing Obligation; Failure to Respond; Objections; Motions., Procedure for Request., The request may, without leave of court, be served on the plaintiff after commencement of the action and on any other party with or after service of the summons and complaint on 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 request may specify the form or forms in which electronically stored information is to be produced. , Procedure for Response., 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. The written response shall be made by the party upon whom it is served if an individual, or, if a governmental, commercial, or charitable entity, by an officer or agent thereof. The person making the response shall swear or certify in the form prescribed by paragraph (c) of this rule that it is complete and accurate based on personal knowledge and/or upon information if provided by others, whose identity and source of knowledge shall be disclosed. The written response shall be served on the requesting party and a copy on all other parties. The written response shall either include the requested documents or other material or state, with respect to each item or category, that inspection and related activities will be permitted as requested. If the written response provides documents to the requesting party, those documents shall be provided to or made available to any other party upon request. Unless the parties otherwise agree, or the court otherwise orders: 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; if a request does not specify the form or forms for producing electronically stored information, a responding party shall produce the information in a form or forms in which it is ordinarily maintained or in a form or forms that are reasonably usable; and a party need not produce the same electronically stored information in more than one form. , Continuing Obligation., If a party who has furnished a written response to a request to produce or who has supplied documents in response to a request to produce thereafter obtains additional documents that are responsive to the request, a supplemental written response and production of such documents, as appropriate, shall be served promptly. , Objections; Failure to Respond; Motions., General objections to the request as a whole are not permitted and shall be disregarded by the court and adverse parties. The party upon whom the request is served may, however, object to a request on specific grounds and, if on the ground of privilege or accessibility of electronically stored information, the objection shall be made in accordance with R. 4:10-2(e) and (f) respectively. The requesting party may move for an order of dismissal or suppression or an order to compel 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. The provisions of R. 4:23-1(c) apply to the award of expenses incurred in relation to motions made pursuant to this rule. , Certification or Affidavit of Completeness., The person responding to the request shall submit with the response a certification stating or affidavit averring as follows: I hereby certify (or aver) that I have reviewed the document production request and that I have made or caused to be made a good faith search for documents responsive to the request. I further certify (or aver) that as of this date, to the best of my knowledge and information, the production is complete and accurate based on ( ) my personal knowledge and/or ( ) information provided by others. I acknowledge my continuing obligation to make a good faith effort to identify additional documents that are responsive to the request and to promptly serve a supplemental written response and production of such documents, as appropriate, as I become aware of them. The following is a list of the identity and source of knowledge of those who provided information to me:, 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., Official Comment (August 1, 2016), Parties may request metadata in electronic documents. Metadata is embedded information in electronic documents that is generally hidden from view in a printed copy of a document. It is generated when documents are created or revised on a computer. Metadata may reflect such information as the author of a document, the date or dates on which the document was revised, tracked revisions to the document, and comments inserted in the margins. It may also reflect information necessary to access, understand, search, and display the contents of documents created in spreadsheet, database, and similar applications. Litigants and lawyers should be aware that metadata may be present in electronic documents produced in discovery. Parties are encouraged to meet and confer about the format in which they will produce electronic documents. Parties also should seek agreement on whether the receiving party may review unrequested metadata in electronic documents. For example, the parties may agree not to “strip” documents of metadata (due to spoliation concerns), or to refrain from reviewing metadata in electronic documents when metadata has not been specifically requested in discovery. If lawyers are permitted to review metadata in electronic documents submitted in discovery, they should agree on the manner in which metadata will be addressed in a privilege log. The selection of the format of electronic documents sought in discovery can determine the amount of metadata to be produced, and significantly affect the cost of discovery. Those considerations should be evaluated in light of the scope and complexity of the case. The burden on the producing party caused by the selection of format of documents sought in discovery should be considered and appropriately balanced against the requesting party’s need for metadata. Judges, when reviewing a motion to compel discovery or for a protective order, should also consider the limitations of Rule 4:10-2(g). If electronic documents are provided in response to a discovery request, the receiving lawyer should consider his or her obligations under Rule of Professional Conduct 4.4(b) before reviewing metadata. Parties have an obligation to preserve metadata in electronic documents, subject to a standard of reasonableness. Note: Source - R.R. 4:24-1. Former rule deleted and new R. 4:18-1 adopted July 14, 1972 to be effective September 5, 1972; rule caption and paragraph (c) amended July 14, 1992 to be effective September 1, 1992; paragraphs (a) and (b) amended July 13, 1994 to be effective September 1, 1994; paragraph (b) amended July 10, 1998 to be effective September 1, 1998; paragraph (b) amended July 5, 2000 to be effective September 5, 2000; paragraph (b) amended July 12, 2002 to be effective September 3, 2002; caption and paragraphs (a) and (b) amended July 27, 2006 to be effective September 1, 2006; paragraph (b) caption amended, paragraph (b) text reallocated and captioned as subparagraphs (b)(1) and (b)(2), subparagraph (b)(2) amended, new subparagraphs (b)(3) and (b)(4) adopted, former paragraph (c) redesignated as paragraph (d), and new paragraph (c) caption and text adopted July 23, 2010 to be effective September 1, 2010; new Official Comment adopted August 1, 2016 to be effective September 1, 2016. Part 4
Reporting Instructions for jurors summonsed on August 28th, 2025, . , , If you are assigned to a trial or are asked to return for continuation of jury selection, you MUST follow the Judge's reporting instructions. , PETIT JURORS:, No Jurors, are required to report on Thursday August 28th, 2025. Your service is complete for 3 years. GRAND JURORS: Grand Jurors who are sworn are required to report to the Hall of Justice. Thank you very much for your willingness to serve as a juror and for helping the Judiciary continue to provide this vital function of our justice system during these extraordinary times. The New Jersey Judiciary does not and has never asked for personal identifiers over the phone, by email, or in person. Court officials will never ask for payment to avoid arrest for failure to report for jury duty. Anyone who has concerns about being approached inappropriately concerning jury duty should contact the county jury manager as well as local law enforcement., Message from Assignment Judge Deborah Silverman Katz, As a juror you play a critical role in our justice system by assuring that disputes are resolved fairly and impartially. I understand that jury service often is an inconvenience and appreciate your willingness to serve. I am sure that through your experience as a juror, you will gain valuable insights into the operation of our courts. Thank you for serving., Health and Safety, If you feel sick, do not report to the courthouse. Instead, contact your local jury management office contact your local jury management office to reschedule your service., Voluntary Demographic Information, The juror questionnaire includes three voluntary demographic questions. This information contact your local jury management office helps the Judiciary understand the diversity and representativeness of jury pools. Your responses to these questions are optional and will not affect your selection. , Americans With Disabilities Act (ADA) Policy, Advise the Jury Management Office if you require an accommodation in order to serve. You can reach the Jury Management Office by phone at or by email at ., Juror Parking Directions, Camden County Hall of Justice 101 South 5th Street Camden, New Jersey 08103 856-650-9100, Parking for Camden County Hall of Justice, Free parking is available for jurors at the juror parking lot, located one block from the Hall of Justice at Parking lot on 100 3rd Street 100 S. 3rd St . (on the corner of Martin Luther King Blvd. and 3rd St.) Take Martin Luther King Blvd. to 3rd Street and make a right. The parking lot will be on your left. Please have your juror information available to show the attendant upon entering the lot., Public Transportation to Camden County Hall of Justice, The PATCO Hi-Speedline stops at Broadway and City Hall stations, one block from the Hall of Justice. NJ Transit stops at Broadway Station or City Hall., Dress Code, Jurors reporting for service should wear clothing appropriate for an appearance in court. Shorts, t-shirts, uniforms or clothing containing statements or offensive symbols are not permitted. All hats must be removed when in a courtroom. Comfortable clothing is also advisable., Courtroom Regulations, Cell phones, pagers and electronic devices must be turned off in the courtroom. You are not permitted to read newspapers or other materials in the courtroom. You are not permitted to bring food or beverages into the courtroom., If You Are Selected As A Juror, The trial judge will instruct you regarding the trial schedule, reporting times, any recesses, lunch arrangements, etc. The judge's instructions will take precedence over any general instructions given in the assembly area. You must wear your juror badge at all times, including during lunch., Other Factors Relating To Your Juror Service, The daily fee for petit jurors is $5 for the first 3 days and $40 for each day after 3 days. The daily fee for grand jurors is $5 for each day of service. Checks are processed on Friday. Your juror check will generally be received within 3 weeks. Check with your employer or your union representative, or read your employee handbook if you have questions about whether you will be compensated by your employer while serving as a juror., Employment Protection, Be aware that N.J.S.A. 2B:20-17 protects jurors from employment related retaliation and provides for the possibility of both criminal and civil sanctions., Term of Service, Please be advised that the term of service for petit jurors is one day or for the duration of one trial if selected. If you are not selected on your date of service and not told by the trial judge to return the following day to complete jury selection, your term of service is completed that day. Once your service is completed, you may request to be excused if summoned again within three years., Smoking Policy, The courthouse is a non-smoking facility. If you leave the courthouse to smoke, you must inform jury staff so that we are aware of your location at all times., Failure to Report, Individuals who fail to respond to a jury summons or fail to report when summoned may be subject to penalties including fines. If you have forgotten to appear as scheduled for jury service, please contact the Jury Management Office immediately at 856-650-9085 .
4:26-4-Fictitious Names; In Personam Actions 4:26-4 In any action, irrespective of the amount in controversy, other than an action governed by R. 4:4-5 (affecting specific property or a res), if the defendant's true name is unknown to the plaintiff, process may issue against the defendant under a fictitious name, stating it to be fictitious and adding an appropriate description sufficient for identification. Plaintiff shall on motion, prior to judgment, amend the complaint to state defendant's true name, such motion to be accompanied by an affidavit stating the manner in which that information was obtained. If, however, defendant acknowledges his or her true name by written appearance or orally in open court, the complaint may be amended without notice and affidavit. No final judgment shall be entered against a person designated by a fictitious name. Note: Source-R.R. 7:4-5 (first paragraph); amended July 15, 1982 to be effective September 13, 1982; amended July 26, 1984 to be effective September 10, 1984; amended July 13, 1994 to be effective September 1, 1994. Part 4
4:27-2-Joinder of Remedies; Fraudulent Conveyances 4:27-2 Except as provided by N.J.S. 2A:50-2 and 2A:50-22 (debt secured by mortgage) and except as otherwise provided by R. 4:7-5 (mandatory crossclaims), if a claim is one heretofore cognizable only after another claim has been prosecuted to a conclusion, then the 2 claims may be joined in a single action, but the court shall grant relief therein only in accordance with the relative substantive rights of the parties. In particular, a plaintiff may state a claim for money and a claim to have set aside a conveyance fraudulent as to plaintiff, without first having obtained a judgment establishing the claim for money. Note: Source-R.R. 4:31-2. Amended July 14, 1972 to be effective September 5, 1972; amended July 16, 1979 to be effective September 10, 1979; amended July 15, 1982 to be effective September 13, 1982; amended July 13, 1994 to be effective September 1, 1994. Part 4
4:25-3-Form of Pretrial Memoranda 4:25-3 Pretrial memoranda shall include the 16 items enumerated in R. 4:25-1(b), set forth in the same sequence and with corresponding numbers, and the following additional items, numbered as indicated: The date the attorneys for the parties conferred and matters then agreed upon; A certification that all pretrial discovery has been completed or, in lieu thereof, a statement as to those matters of discovery remaining to be completed; A statement as to which parties, if any, have not been served and which parties, if any, have defaulted. Note: Source – R.R. 4:29-3(a)(b)(c)(d)(e). Caption amended, paragraph (b) adopted, and former paragraphs (b), (c) and (d) deleted July 7, 1971 to be effective September 13, 1971; paragraph (b) amended July 14, 1972 to be effective September 5, 1972; caption amended, paragraph (a) deleted and caption of paragraph (b) deleted July 13, 1994 to be effective September 1, 1994. Part 4
4:28-2-Claims by or Against Fiduciaries 4:28-2 Claims by or against any fiduciary, as such, may be joined without leave of court with claims by or against the fiduciary personally in respect of or arising out of the fiduciary-ship, and may, with leave of court, be joined with any other claims by or against the fiduciary personally. Note: Source-R.R. 4:32-6; amended July 13, 1994 to be effective September 1, 1994. Part 4
4:25-6-Pretrial Conference After Grant of New Trial 4:25-6 If a new trial is directed by either the trial court or the appellate court, a pretrial conference shall be scheduled if the action was originally pretried and in such other actions as the court directs. Note: Source – R.R. 4:29-7. Part 4
4:35-4-Continuous Trials 4:35-4 Insofar as practicable, all jury and non-jury trials should be continuous and uninterrupted, and should run for the full day as fixed by R. 1:30-3. Note: Adopted July 5, 2000 to be effective September 5, 2000. Part 4
4:39-1-Special Verdicts 4:39-1 The court may require a jury to return only a special verdict in the form of a special written finding upon each issue of fact, in which case it may submit to the jury either written questions which can be categorically or briefly answered or written forms of the several special findings which might properly be made under the pleadings and evidence; or it may use such other method of submitting the issues and requiring written findings thereon as it deems appropriate. The court shall instruct the jury concerning the matters submitted as is necessary to enable it to make its findings upon each issue. If in so doing the court omits any issue of fact raised by the pleadings or by the evidence, each party waives the right to a trial by jury of the issues so omitted unless before the jury retires submission to the jury is demanded. The court may make a finding as to an issue omitted without such demand, or, if it fails to do so, it shall be deemed to have made a finding in accord with the judgment on the special verdict. Note: Source-R.R. 4:50-1; amended July 13, 1994 to be effective September 1, 1994. Part 4
4:39-2-General Verdict Accompanied by Answer to Interrogatories 4:39-2 The court may submit to the jury, together with appropriate forms for a general verdict, written interrogatories upon one or more issues of fact the decision of which is necessary to a verdict. The court shall direct the jury both to make written answers and to render a general verdict, and shall instruct it, as is necessary, to enable it to do so. If the general verdict and the answers are consistent, the court shall direct the entry of the appropriate judgment upon the verdict and answers. When the answers are consistent with each other but one or more is inconsistent with the general verdict, the court may direct the entry of judgment in accordance with the answers, notwithstanding the general verdict, or may return the jury for further consideration of its answers and verdict, or may order a new trial. When the answers are inconsistent with each other and one or more is likewise inconsistent with the general verdict, the court shall not direct the entry of judgment but may return the jury for further consideration of its answers and verdict or may order a new trial. Note: Source-R.R. 4:50-2. Part 4
4:39-3-Omissions in Verdict in Action to Recover Personal Property 4:39-3 If, in an action to recover personal property unlawfully detained, or on an issue concerning several things in one count, the verdict fails to find for part of them, such verdict shall stand, but the plaintiff shall be barred of title to the things omitted. Note: Source-R.R. 4:50-3; amended July 13, 1994 to be effective September 1, 1994. Part 4