N.J. R. Appendices Form C(2)

As amended through April 29, 2024

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.

CERTIFICATION

I hereby certify that the foregoing answers to interrogatories are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.

I hereby certify that the copies of the reports annexed hereto provided by either treating physicians or proposed expert witnesses are exact copies of the entire report or reports provided by them; that the existence of other reports of said doctors or experts are unknown to me, and if such become later known or available, I shall serve them promptly on the propounding party.

N.J. R. Appendices Form C(2)

Note: New form interrogatory adopted June 28, 1996 to be effective 9/1/1996; new introductory paragraph added July 5, 2000 to be effective 9/5/2000; certification amended July 28, 2004 to be effective 9/1/2004.