Form E. Uniform Interrogatories by Plaintiff in Motor Vehicle Collision Case:
Special Civil Part
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).
PLEASE ANSWER THE FOLLOWING QUESTIONS WITH RESPECT TO THE
COLLISION DESCRIBED IN THE PLAINTIFF'S COMPLAINT.
1. Did you own one of the vehicles involved in the accident?
2. Were you driving one of the vehicles involved in the accident?
3. If it was your vehicle, but you were not driving, who was?
4. If it was your vehicle, but you were not driving, what was the driver doing with
your vehicle?
5. If you were not the owner of the vehicle you were driving, give the name,
address and telephone number of the owner.
6. If you were not the owner of the vehicle you were driving, list the vehicles you
owned on the date of the accident.
7. If you were not driving your vehicle, give the name, address and telephone
number of the person who was driving.
8. If you were not the driver, how did the driver get your vehicle and what was the
driver doing with it?
9. List the names and addresses of the occupants of the vehicle and their location
in the vehicle.
10. List the registration number, year, make and model of the vehicles involved in
the collision.
11. Give details of the accident: A) date; B) time; C) weather; D) visibility and E)
road condition.
12. Where did the accident happen? Street and town.
13. Which street was your vehicle on at the time of the accident?
14. Which way was your vehicle going at the time of the accident?
15. Where on the roadway did the collision take place? You may include a sketch
for greater clarity.
16. Please state: A) How did this accident happen? B) Who was at fault and how?
C) Any other factors you believe contributed to the accident.
17. Did the other driver break any laws? If so, which laws?
18. Please state: A) Were there traffic lights, signs, or other controls for any of the
vehicles involved in the accident? B) What kind of lights, signs or controls? C) Where
were they? D) Who were they for?
19. Please state: A) Did the accident happen in an intersection? B) Who was in the
intersection first? C) Did your vehicle stop before it entered the intersection? D) How fast
was your vehicle going when it entered the intersection?
20. Please state: A) How far was your vehicle from the other vehicle when it was
first seen? B) How fast was your vehicle going when the other vehicle was first seen? C)
How fast was the other vehicle going when it was first seen?
21. After the accident where did the vehicles stop?
22. State what part of your vehicle came into contact with what part of the other
vehicle or vehicles involved.
23. List the names and addresses of anyone who may have direct knowledge of
any facts relating to the collision or case. Include in your answer eyewitnesses and
experts or other witnesses who may testify at trial. Attach copies of expert reports, if any.
24. State whether you had insurance at the time of the accident. If yes, state name
and address of all insurance companies and policy numbers.
