Interrogatories are written questions that one side in a lawsuit sends to the other, to be answered in writing and under oath. In New Jersey injury cases they are usually the first big piece of homework for the injured person, and careful answers set up everything that follows.

Key rules

  • Interrogatories are governed by N.J. Court Rule 4:17.
  • In many personal injury cases, the court rules supply standard "Form A" questions (Appendix II to the Rules of Court), and the parties may add only a limited number of extra questions.
  • Answers are generally due within 60 days after they are served (R. 4:17-4(b)).
  • You sign a certification that your answers are true, and you have a continuing duty to update them if things change (R. 4:17-7).

What they ask

Standard injury-case interrogatories cover topics like:

  • Your personal background, address history and employment.
  • How the accident happened, in your words.
  • Names of witnesses and anyone with knowledge of the facts.
  • Every injury you claim and every doctor, hospital and therapist who treated you.
  • Prior and later accidents, injuries and claims.
  • Lost wages and other financial losses, with documentation.
  • Photos, statements and other evidence you have.
  • Expert witnesses you plan to use, and their reports.

How to answer well

  1. Be complete. If you leave out a doctor or a prior injury, the defense will find it in records and use the omission to attack your credibility.
  2. Be accurate, not perfect. If you don't know an exact date, say "approximately."
  3. Answer in your own words with your lawyer. Your lawyer will draft and refine answers with you, make proper objections, and attach documents.
  4. Stay consistent. Your deposition will cover the same ground, and the defense will compare the two.
  5. Update them. New treatment, a new surgery recommendation or a new expert report must be added through amended answers. Late disclosure can lead a judge to bar that evidence.

What if someone doesn't answer?

If a party fails to answer, the other side can ask the court to dismiss or suppress that party's claims or defenses, usually first without prejudice so the party has a chance to cure the problem (R. 4:23-5). That is why deadlines matter, on both sides.

Other written discovery

Interrogatories usually travel with:

  • Requests for documents (R. 4:18), such as medical records, photos and wage records.
  • Requests for admissions (R. 4:22), asking a party to admit or deny specific facts.
  • Authorizations so the defense can collect your medical and employment records directly.

For the full timeline, see the steps in a New Jersey personal injury lawsuit.

General information about New Jersey civil procedure, not legal advice. Deadlines can be extended by agreement or court order; confirm yours with your lawyer.