Form C(3). Uniform Interrogatories to be Answered by Defendant Physicians in
Medical Malpractice 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. Identify and describe the appearance of each and every person who was present
in the vicinity of the alleged occurrence, giving the name, address and occupation of each
such person and stating your relationship to each.
2. Describe in detail all aspects of your professional medical relationship with the
plaintiff, indicating the date of commencement, the nature and extent of your medical
relationship prior to the alleged occurrence, and the date and circumstances of the
termination of your professional medical relationship.
3. In reference to the condition that forms the basis of the complaint, set forth:
(a) the date(s) and circumstances under which you saw plaintiff;
(b) any and all medical history given to you;
(c) the examination(s) conducted of the plaintiff;
(d) your findings on each examination;
(e) your prognosis and diagnosis following each examination; and
(f) any treatment or medication prescribed.
4. Attach your Curriculum Vitae or describe in detail your education, training,
experience, published materials, service on boards and committees, continuing education
and certifications, prior work and hospital affiliations, licenses and specialties.
5. Have your full rights or privileges to practice medicine been suspended,
revoked or terminated in any state or hospital since you started to practice medicine? If
the answer to this question is in the affirmative, state:
(a) the reason why your full rights or privileges to practice medicine or any
hospital association were suspended, revoked or terminated; and
(b) the name of the state or hospital that suspended, revoked or terminated your
full rights or privileges to practice medicine.
6. If you have ever been a defendant in a malpractice suit other than the present
one, identify the case by name, court and docket number, and summarize the allegations
against you and the outcome of the case, including the terms of any settlement.
7. Attach a complete copy of any written records or documents that you have
regarding plaintiff, along with a typed transcription of any handwritten records and
documents.
8. Attach a copy of all documents that the plaintiff signed consenting to any
treatment or procedures performed or prescribed by you, as well as a copy of any
literature, material, pamphlets, instructions or other information or documents that you
supplied to plaintiff.
9. List all risks that you described to the plaintiff with respect to any treatment or
procedures you prescribed or performed.
10. If you contend that the plaintiff's injuries were caused in whole or in part by
an inherent defect in a drug, instrument, implement or other type of product or substance,
identify each such allegedly defective item, including in your identification:
(a) a complete description of its appearance, and appearance of its container or
wrapper, if any;
(b) the name and address of its manufacturer;
(c) the name and address of the dealer or seller who sold it to the person who
owned it at the time of the alleged occurrence;
(d) the name, occupation, title, address and professional relationship to you of the
person who owned it at the time of the occurrence;
(e) a description of the use to which it is normally put;
(f) its serial number, batch number or other specific identifying characteristics;
and
(g) the medical name for this product and a lay description of it and its use.
11. If there were any reviews performed, including investigations undertaken,
hearings held or reports prepared, by the hospital, its medical staff or any officer,
committee or agency of the hospital or any public body or other person or persons
concerning the condition that forms the basis of the complaint, state:
(a) the name and position of the person, persons or committee that performed the
review;
(b) the date and time of each review;
(c) the name, address, profession or professional relationship to you of all persons
present at each review;
(d) the nature and purpose of each review;
(e) whether the review was recorded; and
(f) the name and address of each person who has any records concerning each
review.
12. Did you refer to or rely upon any medical texts or publications in connection
with the diagnosis or treatment of plaintiff? If so, identify those items by title, author and
publisher.
13. If you or your expert intend to rely on or use in any way at trial any treatise,
identify the treatise by title, author and edition and indicate the pertinent portions to be
relied on or used at trial.
14. If you claim that the alleged occurrence resulted from the plaintiff's own lack
of care, set forth as fully and specifically as you can what acts, conduct or omissions
constituted such lack of due care.
15. State the names and addresses of all consultants or other physicians who saw,
examined and treated plaintiff at your request for the condition forming the basis of the
complaint, and in relation to all such consultations or examinations by other physicians
indicate:
(a) the reason you requested consultations or further examination;
(b) when the consultation or examination took place; and
(c) all opinions or reports rendered to you by the consultant or examining
physician.
16. The plaintiff in the complaint alleges that while under your care he/she
sustained the injury and disability which is the subject matter of this lawsuit. In relation
to such injury and disability, indicate in your opinion the cause of that injury and
disability.
