APPENDIX II. INTERROGATORY FORMS
Form A. Uniform Interrogatories to be Answered by Plaintiff in All Personal Injury
Cases:Superior Court
All questions must be answered unless the court otherwise orders or unless a
claim of privilege or protective order is made in accordance with R. 4:17-1(b)(3).
(Caption)
1. Full name, present address and date of birth.
2. Describe in detail your version of the accident or occurrence setting forth the
date, location, time and weather.
3. Detailed description of nature, extent and duration of any and all injuries.
4. Detailed description of injury or condition claimed to be permanent together
with all present complaints.
5. If confined to a hospital, state its name and address, and dates of admission and
discharge.
6. If any diagnostic tests were performed, state the type of test performed, name
and address of place where performed, date each test was performed and what each test
disclosed. Attach a copy of the test results.
7. If treated by any health care provider, state the name and present address of
each health care provider, the dates and places where treatments were received and the
date of last treatment. Attach true copies of all written reports provided to you by any
such health care provider whom you propose to have testify in your behalf.
8. If still being treated, the name and address of each doctor or health care
provider rendering treatment, where and how often treatment is received and the nature of
the treatment.
9. If a previous injury, disease, illness or condition is claimed to have been
aggravated, accelerated or exacerbated, specify in detail the nature of each and the name
and present address of each health care provider, if any, who ever provided treatment for
the condition.
10. If employed at the time of the accident, state: (a) name and address of
employer; (b) position held and nature of work performed; (c) average weekly wages for
past year; (d) period of time lost from employment, giving dates; and (e) amount of
wages lost, if any.
11. If there has been a return to employment or occupation, state: (a) name and
address of present employer; (b) position held and nature of work performed; and (c)
present weekly wages, earning, income or profit.
12. If other loss of income, profit or earnings is claimed: (a) state total amount of
the loss; (b) give a complete detailed computation of the loss; and (c) state the nature and
source of the loss of income, profit and earnings, and the dates of the deprivation.
13. Itemize in complete detail any and all moneys expended or expenses incurred
for hospitals, doctors, nurses, diagnostic tests or health care providers, x-rays, medicines,
care and appliances and state the name and address of each payee and the amount paid
and owed each payee.
14. Itemize any and all other losses or expenses incurred not otherwise set forth.
15. Identify all documents that may relate to this action, and attach copies of each
such document.
16. State the names and addresses of all eyewitnesses to the accident or
occurrence, their relationship to you and their interest in this lawsuit.
17. State the names and addresses of all persons who have knowledge of any facts
relating to the case.
18. If any photographs, videotapes, audio tapes or other forms of electronic
recording, sketches, reproductions, charts or maps were made with respect to anything
that is relevant to the subject matter of the complaint, describe: (a) the number of each;
(b) what each shows or contains; (c) the date taken or made; (d) the names and addresses
of the persons who made them; (e) in whose possession they are at present; and (f) if in
your possession, attach a copy, or if not subject to convenient copying, state the location
where inspection and copying may take place.
19. If you claim that the defendant made any admissions as to the subject matter
of this lawsuit, state: (a) the date made; (b) the name of the person by whom made; (c)
the name and address of the person to whom made; (d) where made; (e) the name and
address of each person present at the time the admission was made; (f) the contents of the
admission; and (g) if in writing, attach a copy.
20. If you or your representative and the defendant have had any oral
communication concerning the subject matter of this lawsuit, state: (a) the date of the
communication; (b) the name and address of each participant; (c) the name and address of
each person present at the time of such communication; (d) where such communication
took place; and (e) a summary of what was said by each party participating in the
communication.
21. If you have obtained a statement from any person not a party to this action,
state: (a) the name and present address of the person who gave the statement; (b) whether
the statement was oral or in writing and if in writing, attach a copy; (c) the date the
statement was obtained; (d) if such statement was oral, whether a recording was made,
and if so, the nature of the recording and the name and present address of the person who
has custody of it; (e) if the statement was written, whether it was signed by the person
making it; (f) the name and address of the person who obtained the statement; and (g) if
the statement was oral, a detailed summary of its contents.
22. If you claim that the violation of any statute, rule, regulation or ordinance is a
factor in this litigation, state the exact title and section.
23. State the names and addresses of any and all proposed expert witnesses. Set
forth in detail the qualifications of each expert named and attach a copy of each expert’s
current resume. Also attach true copies of all written reports provided to you by any such
proposed expert witnesses.
With respect to all expert witnesses, including treating physicians, who are
expected to testify at trial and with respect to any person who has conducted an
examination pursuant to Rule 4:19, who may testify, state each such witness's name,
address and area of expertise and attach a true copy of all written reports provided to you.
State the subject matter on which your experts are expected to testify.
State the substance of the facts and opinions to which your experts are expected to
testify and a summary of the grounds for each opinion.
24. State whether you have ever been convicted of a crime.YES ( ) or NO ( ).
If the answer is “yes”, state: (a) date; (b) place; and (c) nature.
TO BE ANSWERED ONLY IN AUTOMOBILE ACCIDENT CASES
25. Do you have insurance coverage and/or PIP benefits under an applicable
policy or policies of automobile insurance? As to each such policy provide the name and
address of the insurance carrier, policy number, the named insured and attach a copy of
the declaration sheet.
If you are making a claim for property damage to a motor vehicle, provide
answers to the uniform interrogatories contained in Form B, questions 1 through 18.
