Civil Court Rules and Jury Charges

Kenneth Vercammen & Associates, P.C.
2053 Woodbridge Avenue - Edison, NJ 08817

Monday, August 24, 2009

Form C(1). Uniform Interrogatories to be Answered by Defendant in Automobile Accident Cases Only: Superior Court

Form C(1). Uniform Interrogatories to be Answered by Defendant in Automobile
Accident Cases Only: 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. With respect to the vehicle involved in the incident referred to in the complaint:

Underline Answer
(a)Do you admit ownership? Yes No
(b)Do you admit operation? Yes No
(c)Do you admit agency? Yes No
(d)Do you admit control? Yes No
(e)Do you admit the date and place? Yes No
2. If you do not admit ownership, state: (a) the name and address of the owner; (b)
whether you were operating the motor vehicle with permission of the owner; and (c) the
registration number, year, make, model and color of each motor vehicle owned by you on
the date of the collision as alleged in the complaint.
3. If you do not admit operation, state the name and address of the operator.
4. If you do not admit agency and the owner was not also the operator, state: (a)
the circumstances under which the vehicle came into the possession of the operator; (b)
the purpose for which the vehicle was being used; and (c) its destination.
5. If you do not admit control: (a) state the name and address of the one in control;
and (b) if control was in another by agreement, state the names and addresses of the
parties to the agreement, whether the agreement was oral or written and briefly, the terms
of the agreement.
6. If you do not admit the date and place of the collision as alleged in the
complaint, state the date and place of the collision as you recall it.
7. State whether your vehicle was licensed under an Interstate Commerce
Commission permit. YES ( ) or NO ( ).
If the answer is “yes”, state: (a) the number of such permit; (b) the name and
address of the permittee; and (c) the name and address of the lessee or other person in
control, if any.
(Note: The term “your vehicle” in this and other questions herein has reference to
the vehicle in which you were an occupant at the time of the collision.)
8. State on what street, highway, road or other place (designate which) and in
what general direction (north, south, east or west) your vehicle was proceeding
immediately prior to the collision. (You may include a sketch for greater clarity.)
9. With respect to fixed objects at the location of the collision, state as nearly as
possible the point of impact. If you included a sketch, place an X thereon to denote the
point of impact.
(Note: The term “point of impact” as used in this and other questions has
reference to the exact point on the street, highway, road or other place where the vehicles
collided.)
10. State whether there were any traffic control devices, signs or police officers at
or near the place of the collision. If there were, describe them (i.e., traffic lights, stop
sign, police officers, etc.) and state the exact location of each.
11. If you contend that there was a malfunction of a motor vehicle or equipment,
state: (a) make, model and year of the motor vehicle and whether or not that vehicle was
equipped with power brakes and steering; (b) the nature of the malfunction; (c) the date
the motor vehicle was purchased and the name and address of the person from whom the
motor vehicle was purchased; (d) the date that that portion of the motor vehicle in which
the malfunction occurred was last inspected and the name and address of the person
inspecting same; (e) the last date prior to the accident that that portion of the motor
vehicle was repaired or replaced, the nature and extent of the repairs, the name
and address of the person repairing or replacing same; (f) if the motor vehicle was
repaired after the accident, state the name and address of the person repairing same and
the nature of the repairs; and (g) attach a copy of any repair bills.
12. If the collision occurred at an uncontrolled intersection, state: (a) which
vehicle entered the intersection first; (b) whether your vehicle came to a full stop before
entering the intersection; and (c) if your vehicle did not come to a full stop before
entering the intersection, state the speed of your vehicle when it entered the intersection.
13. State in terms of feet the distance between: (a) the front of your vehicle and
the point of impact at the time you first observed the other vehicle or vehicles collided
with, and state your speed at that time; (b) the front of the other vehicle or vehicles
collided with and the point of contact at the time you first observed it or them and state its
or their speed at that time; and (c) your vehicle and the vehicle or vehicles collided with
at the time you first saw it or them.
14. State where each vehicle came to rest after the impact. Include the distance in
terms of feet from the point of impact to the point where each vehicle came to rest.
15. State what part of your vehicle came into contact with what part of the other
vehicle or vehicles involved.
16. State the following facts with respect to the collision: (a) time; (b) condition
of weather; (c) condition of visibility; and (d) condition of roadway.
17. State the names and addresses of all persons occupying your vehicle.
18. Did you observe the plaintiff's vehicle prior to the accident? YES ( ) or NO ( ).
If the answer is “yes”, set forth the time that elapsed from the time you first saw
the plaintiff's vehicle until the impact occurred.
19. At the time of the impact, state the speeds of all vehicles involved in the
collision.
20. Were you charged with a motor vehicle violation as a result of the collision?
YES ( ) or NO ( ).
If the answer is “yes”, state: (a) charge; (b) plea; and (c) disposition.