CT · rules
Conn. Practice Book Form 201
Plaintiff’s Interrogatories
The undersigned, on behalf of the Plaintiff, hereby propounds the following interrogatories to be
answered by the Defendant, _______________, under oath, within sixty (60) days of the filing hereof
in compliance with Practice Book Section 13-2.
Definition: ‘‘Y ou’’ shall mean the Defendant to whom these interrogatories are directed except that
if that Defendant has been sued as the representative of the estate of a decedent, ward, or incapable
person, ‘‘you’’ shall also refer to the Defendant’s decedent, ward or incapable person unless the context
of an interrogatory clearly indicates otherwise.
In answering these interrogatories, the Defendant(s) is (are) required to provide all information within
their knowledge, possession or power. If an interrogatory has subparts, answer each subpart separately
and in full and do not limit the answer to the interrogatory as a whole. If any interrogatories cannot be
answered in full, answer to the extent possible.
(1) State the following:
(a) your full name and any other name(s) by which you have been known;
(b) your date of birth;
(c) your motor vehicle operator’s license number;
(d) your home address;
(e) your business address;
(f) if you were not the owner of the subject vehicle, the name and address of the owner or lessor
of the subject vehicle on the date of the alleged occurrence.
(2) Have you made any statements, as defined in Practice Book Section 13-1, to any person regarding
any of the incidents alleged in the Complaint?
COMMENT:
This interrogatory is intended to include party statements made to a representative of an insurance company prior to involvement
of defense counsel.
(3) If the answer to Interrogatory #2 is affirmative, state:
(a) the name(s) and address(es) of the person or persons to whom such statements were made;
(b) the date on which such statements were made;
(c) the form of the statement (i.e., whether written, made by recording device or recorded by a
stenographer, etc.);
(d) the name and address of each person having custody, or a copy or copies of each statement.
(4) State the names and addresses of all persons known to you who were present at the time of
the incident alleged in the Complaint or who observed or witnessed all or part of the incident.
No. CV-
(Plaintiff)
VS.
(Defendant)
: SUPERIOR COURT
: JUDICIAL DISTRICT OF
: AT
: (Date)
(5) As to each individual named in response to Interrogatory #4, state whether to your knowledge,
or the knowledge of your attorney, such individual has given any statement or statements as defined
in Practice Book Section 13-1 concerning the subject matter of the Complaint in this lawsuit. If your
answer to this interrogatory is affirmative, state also:
(a) the date on which the statement or statements were taken;
(b) the name(s) and address(es) of the person or persons who took such statement or statements;
(c) the name(s) and address(es) of any person or persons present when such statement or statements were taken;
(d) whether such statement or statements were written, made by recording device or taken by a
court reporter or stenographer;
(e) the name(s) and address(es) of any person or persons having custody or a copy or copies of
such statement or statements.
(6) Are you aware of any photographs or any recordings by film, video, audio or any other digital
or electronic means depicting the incident alleged in the Complaint, the scene of the incident, any
vehicle involved in the incident alleged in the Complaint, or any condition or injury alleged to have
been caused by the incident alleged in the Complaint? If so, for each set of photographs or each
recording taken, obtained or prepared of each such subject, please state:
(a) the name and address of the person who took, obtained or prepared such photograph or recording,
other than an expert who will not testify at trial;
(b) the dates on which such photographs were taken or such recordings were obtained or prepared;
(c) the subject (e.g., ‘‘Plaintiff’s vehicle,’’ ‘‘scene,’’ etc.);
(d) the number of photographs or recordings;
(e) the nature of the recording (e.g., film, video, audio, etc.).
(7) If, at the time of the incident alleged in the Complaint, you were covered by an insurance policy
under which an insurer may be liable to satisfy part or all of a judgment or reimburse you for payments
to satisfy part or all of a judgment, state the following:
(a) the name(s) and address(es) of the insured(s);
(b) the amount of coverage under each insurance policy;
(c) the name(s) and address(es) of said insurer(s).
(8) If at the time of the incident which is the subject of this lawsuit you were protected against the type
of risk which is the subject of this lawsuit by excess umbrella insurance, or any other insurance, state:
(a) the name(s) and address(es) of the named insured(s);
(b) the amount of coverage effective at this time;
(c) the name(s) and address(es) of said insurer(s).
(9) State whether any insurer, as described in Interrogatories #7 and #8 above, has disclaimed/
reserved its duty to indemnify any insured or any other person protected by said policy.
(10) If applicable, describe in detail the damage to your vehicle.
(11) If applicable, please state the name and address of an appraiser or firm which appraised or
repaired the damage to the vehicle owned or operated by you.
(12) If any of the Defendants are deceased, please state the date and place of death, whether an
estate has been created, and the name and address of the legal representative thereof.
(13) If any of the Defendants is a business entity that has changed its name or status as a business
entity (whether by dissolution, merger, acquisition, name change, or in any other manner) since the
date of the incident alleged in the Complaint, please identify such Defendant, state the date of the
change, and describe the change.
(14) If you were the operator of any motor vehicle involved in the incident that is the subject of this
action, please state whether, at the time of the incident, you were operating that vehicle in the course
of your employment with any person or legal entity not named as a party to this lawsuit, and, if so,
state the full name and address of that person or entity.
(15) If you were the operator of any motor vehicle involved in the incident that is the subject of this
action, please state whether you consumed or used any alcoholic beverages, drugs or medications
within the eight (8) hours next preceding the time of the incident alleged in the Complaint and, if so,
indicate what you consumed or used, how much you consumed, and when.
(16) Please state whether, within eight (8) hours after the incident alleged in the Complaint, any
testing was performed to determine the presence of alcohol, drugs or other medications in your blood,
and, if so, state:
(a) the name and address of the hospital, person or entity performing such test or screen;
(b) the date and time;
(c) the results.
(17) Please identify surveillance material discoverable under Practice Book Section 13-3 (c), by
stating the name and address of any person who obtained or prepared any and all recordings by film,
photograph, video, audio or any other digital or electronic means, of any party concerning this lawsuit
or its subject matter, including any transcript thereof which are in your possession or control or in the
possession or control of your attorney, and state the date on which each such recordings were obtained
and the person or persons of whom each such recording was made.
(18) If you were the operator of any motor vehicle involved in the incident that is the subject of this
action, please state whether you were using a cell phone for any activity including, but not limited to,
calling, texting, emailing, posting, tweeting, or visiting sites on the Internet for any purpose, at or
immediately prior to the time of the incident.
PLAINTIFF,
BY___________________________
I, ___________, hereby certify that I have reviewed the above interrogatories and responses thereto
and that they are true and accurate to the best of my knowledge and belief.
_____________________________
(Defendant)
Subscribed and sworn to before me this ____________day of ____________, 20 ___.
_____________________________
Notary Public/
Commissioner of the Superior Court
CERTIFICATION
I certify that a copy of this document was or will immediately be mailed or delivered electronically
or non-electronically on (date) ______to all attorneys and self-represented parties of record and that
written consent for electronic delivery was received from all attorneys exempt from e-filing and self-represented parties of record who received or will immediately be receiving electronic delivery.
Name and address of each party and attorney that copy was or will immediately be mailed or
delivered to*
*If necessary, attach additional sheet or sheets with the name and address which the copy was or
will immediately be mailed or delivered to.
_________________________________________________________________________________
Signed (Signature of filer ) Print or type name of person signing Date Signed
_________________________________________________________________________________
Mailing address ( Number, street, town, state and zip code ) or Email address, if applicable Telephone number
HISTORY—2026: In the first sentence of the certification, “exempt from e-filing” was added after “from all attorneys.”
COMMENTARY—2026: The changes to this form are consistent with the changes to the proof of service language in Section
10-14 (a).
History
(P.B. 1978-1997, Form 106.10A.) (Amended June 21, 2004, to take effect Jan. 1, 2005; amended June 29, 2007, to take effect Jan. 1, 2008; amended June 14, 2013, to take effect Jan. 1, 2014; amended June 13, 2014, to take effect Jan. 1, 2015; amended June 24, 2016, to take effect Jan. 1, 2017; amended June 23, 2017, to take effect Jan. 1, 2018; amended June 12, 2025, to take effect Jan. 1, 2026.)
Provenance
- Source
- jud.ct.gov
- Retrieved
- 2026-09-15
- Edition
- 2026-09-15
- Content hash
181eb8c290a64f74200c050646b609ac146624dbda340ef6f3b3baababdd8de8
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