Form C(2). Uniform Interrogatories to be Answered by Defendant in Falldown
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. If the accident or occurrence took place on or about any particular premises,
area or location, or involved the use or presence of any object, thing, vehicle, equipment
or property, state the name and address of the owner thereof.
2. If anyone other than the owner had any interest, custody, or possession or was
in charge of such premises, area, location, object, thing, vehicle, equipment or property,
state: (a) the name and address of such person, firm or corporation; and (b) the nature and
extent of such interest, custody, possession or charge.
3. If you were not present at the time of the accident or occurrence, state: (a)
whether you had notice or knowledge thereof; (b) when, where, in what manner and from
whom such notice or knowledge was received or acquired; and (c) whether there was any
person(s) acting on your behalf present on the premises at the time of plaintiff's injury
and, if so, include their name(s) and address(es).
4. If prior to the accident or occurrence, you had actual notice or knowledge of the
conditions, artificial or natural, alleged by the plaintiff to have caused or resulted in the
accident or occurrence, state: (a) on what date you had such actual notice or first acquired
such knowledge; and (b) the manner in which such notice or knowledge was received or
acquired.
5. If the complaint or any answers to interrogatories by plaintiff allege that
artificial conditions caused or resulted in the accident or occurrence or was causally
related thereto, state when and by whom such artificial conditions were created.
6. If you had notice of or were in any manner made aware of any such artificial
conditions, state when and what steps you took to eliminate them or make them safe or
give any notice of their existence.
7. Do you, or does any person acting on your behalf, have any reports concerning
the occurrence of plaintiff's injury? YES ( ) or NO ( ).
If the answer is “yes”, state: (a) the full name, present or last known address and
telephone number of the person making it; (b) the date made; (c) the purpose of each
report, including, but not limited to, investigatory or accident report; (d) the field of
expertise and relationship to you of the person making it; (e) whether or not it was made
in the regular course of business; (f) the findings; (g) whether it was written or oral; and
(h) if written, attach a copy hereto, and if oral, set forth the substance thereof.
8. State whether any repairs were made to the premises or property after plaintiff's
injury. YES ( ) or NO ( ).
If the answer is “yes”, state: (a) the full name and present or last known address of
each person who endeavored to correct the condition; (b) indicate the nature of the work
performed; and (c) describe in detail the exact nature and location of the condition as it
was found to exist prior to any work performed.
9. Do you claim that plaintiff was not lawfully on said premises at the time of the
occurrence of the injury? YES ( ) or NO ( ).
If the answer is “yes”, state: (a) what you claim to be the legal status of plaintiff at
said time; and (b) the factual basis of your claim.
