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Under Rule -2(d)(3) of the New Jersey Court Rules, discovery of consulting experts may only be had upon a showing of exceptional circumstances under which it is impractical for the party seeking discovery to obtain facts or opinions on the same subject by other means.

Pursuant to Rule -4(f), a plaintiff or a counterclaimant seeking damages for personal injuries must serve, ?contemporaneous with his or her answers to interrogatories, an executed form authorizing disclosure to the opposing party or parties, for purposes of litigation,? pursuant to the Health Insurance Portability ...

Except as otherwise provided by R. -5 (foreclosure actions) and R. -4 (summary actions), a pleading may state as a counterclaim any claim against the opposing party whether or not arising out of the transaction or occurrence that is the subject matter of the opposing party's claim.

The plaintiff, plaintiff's attorney or the clerk of the court may issue the summons. If a summons is not issued within 15 days from the date of the Track Assignment Notice, the action may be dismissed in ance with R. -2(a).

-4(c), objection may be made at the trial or hearing to receiving in evidence any deposition or part thereof for any reason which would require the exclusion of the evidence if the witness were then present and testifying.

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.