Form C. Uniform Interrogatories to be Answered by Defendant 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. State: (a) the full name and residence address of each defendant; (b) if a
corporation, the exact corporate name; and (c) if a partnership, the exact partnership
name and the full name and residence address of each partner.
2. Describe in detail your version of the accident or occurrence setting forth the
date, location, time and weather.
3. If you intend to set up or plead or have set up or pleaded negligence or any
other separate defense as to the plaintiff or if you have or intend to set up a
counterclaim, cross-claim, or third-party action, (a) state the facts upon which you
intend to predicate such defenses, counterclaim, cross-claim, or third-party action;
and (b) identify a copy of every document relating to such facts.
4. State the names and addresses of all persons who have knowledge of any
relevant facts relating to the case.
5. State (a) the name and address of any person who has made a statement
regarding this lawsuit; (b) whether the statement was oral or in writing; (c) the date the
statement was made; (d) the name and address of the person to whom the
statement was made; (e) the name and address of each person present when the
statement was made; and (f) the name and address of each person who has
knowledge of the statement.
Unless subject to a claim of privilege, which must be specified: (g) attach a copy
of the statement, if it is in writing; (h) if the statement was oral, state whether a
recording was made and, if so, set forth the nature of the recording and the name
and address of the person who has custody of it; and (i) if the statement was oral
and no recording was made, provide a detailed summary of its contents
6. If you claim that the plaintiff made any statements or 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.
7. If you contend that the plaintiff's damages were caused or contributed to by the
negligence of any other person, set forth the name and address of the other person
and the facts upon which you will rely in establishing that negligence.
8. State the names and addresses of all eyewitnesses to the accident or occurrence,
their relationship to you and their interest in this lawsuit.
9. 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.
10. 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, 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 provide a summary of the factual grounds for each opinion.
11. If you contend or intend to contend at the time of trial that the plaintiff
sustained personal injuries in any prior or subsequent accident, state: (a) the date of said
accident; (b) the injuries you contend that plaintiff sustained; (c) the parties
involved in said accident; (d) the source from which you obtained the
information; and (e) attach a copy of any written documents regarding this
information.
12. If you intend to rely on any statute, rule, regulation or ordinance, state the
exact title and section.
13. Pursuant to R. 4:10-2(b), state whether there are any insurance agreements
including excess policies under which any person or firm carrying on an insurance
business may be liable to satisfy part or all of a judgment that may be entered in
this action or to indemnify or reimburse for payments made to satisfy the judgment. YES
(____) or NO (____).
If the answer is "yes", attach a copy of each insurance agreement or policy, or in
the alternative state: (a) number; (b) name and address of insurer or issuer; (c)
inception and expiration dates; (d) names and addresses of all persons insured
thereunder; (e) personal injury limits; (f) property damage limits; (g) medical
payment limits; (h) name and address of person who has custody and possession
thereof; and (i) where and when each policy or agreement can be inspected and
copied.
14. Identify all documents that may relate to this action, and attach copies of each
such document.
15. 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.
