New Jersey Uniform Interrogatories - Form A(1)

Form A(1).

Uniform Interrogatories to Be Answered by Plaintiff

in Medical Malpractice Cases

Only New Jersey Superior Court ¹

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).

1. State your full name, address, date, and place of birth and Social Security number.

2. State the date on which you first came under the medical care of the defendant(s).

3. State the reason(s) you first consulted the defendant(s).

4. State in detail the medical history you gave the defendant(s).

5. Describe the examination performed by the defendant(s) the first time you came under defendant’s medical care.

6. Set forth each date on which you presented yourself to defendant(s) for examination and/or treatment and describe in detail the treatment given to you on each date.²

7. State the name of each defendant that you contend was negligent, and state what you contend that each such defendant did that should not have been done and what you contend that each defendant did not do that should have been done, and the dates thereof. Set forth all facts on which you base your contentions. If you are relying on any written documents or records, identify those documents and records, and state the material in each document which you contend demonstrates negligence.³

8. State the names and addresses of all persons having knowledge of relevant facts relating to this lawsuit and specify those who are eyewitnesses to any act of negligence.

9. State the names and addresses of any and all proposed expert witnesses. Set forth in detail the qualifications of each expert named and attach a copy of each expert’s current resume. Also attach true copies of all written reports provided to you by any such proposed expert witnesses. With respect to all expert witnesses, including treating physicians, who are expected to testify at trial, and with respect to any person who has conducted an examination pursuant to Rule 4:19, state each such witness’s name, address and area of expertise and attach a true copy of all written reports provided to you. State the subject matter on which your experts are expected to testify. State the substance of the facts and opinions to which your experts are expected to testify and provide a summary of the factual grounds for each opinion.⁴

10. Unless for purposes of impeachment, if you or your expert intend to rely on or use in any way at trial any...