Motion Needed for Discovery to be Completed Beyond 60-Day Consent
Period
Rule 4:24-1 provides that a 60-day extension of discovery is automatic if all parties consent; if additional discovery is needed, a motion must be made. Thus, if an IME (independent medical exam) is scheduled to occur, say, six months in the future, and this date is well past the discovery end date, a motion must nonetheless be filed even if all parties agree to the scheduled IME date. The parties may not merely submit a consent order setting out with specificity what discovery remains to be done and when each element will be completed; however, if the adversary consents to an extension greater
than 60 days, that should be stated in the motion.
More information can be obtained from “ A PRACTITIONER’S GUIDE TO NEW JERSEY’S CIVIL COURT PROCEDURES”
KENNETH VERCAMMEN & ASSOCIATES, PC
ATTORNEY AT LAW
2053 Woodbridge Ave.
Edison, NJ 08817
(Phone) 732-572-0500
(Fax) 732-572-0030
Personal Injury Dept.: 732-572-0024
website: www.njpersonalinjurylawcenter.com
