Conn. Practice Book Form 213

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.

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 whether the Plaintiff or Plaintiffs were insured by you for purposes of uninsured/underinsured

motorist coverage with regard to this incident under the policy.

(2) If the answer to the preceding interrogatory is other than ‘‘yes,’’ please state each reason for

which you contend that such Plaintiff(s) were not so insured.

(3) Identify each policy of motor vehicle liability insurance, excess liability insurance, and/or umbrella

liability insurance, of which you are aware, that provided coverage to the alleged tortfeasor(s) or the

vehicle owned or operated by the alleged tortfeasor(s), his, her, its, or their agents, servants, and/or

employees, with regard to this incident, stating:

(a) The name and address of each such insurer;

(b) The named insured(s);

(c) The policy number;

(d) The effective dates;

(e) The limits of uninsured/underinsured motorist coverage under such policy (including per person

and per accident limits, if applicable); and

(f) The basis for contending that said alleged tortfeasor(s) are covered under said policy, including

a brief description of any documents supporting that contention, and the names and addresses of any

witnesses supporting that contention.

(4) State the limits of uninsured/underinsured motorist coverage available under the policy (including

per person and per accident limits, if applicable), which you issued.

(5) State whether the policy affords uninsured/underinsured motorist conversion coverage, pursuant

to General Statutes § 38a-336a.

(6) With regard to each credit, setoff, reduction, or deduction, which you contend lowers the maximum

amount that you could be required to pay any plaintiff below the limits of the uninsured/underinsured

motorist coverage as stated on the declarations page of the policy, state:

No. CV- : SUPERIOR COURT

(Plaintiff): JUDICIAL DISTRICT OF

VS. : AT

(Defendant): (Date)

(a) The policy provision providing for said credit, setoff, reduction, or deduction;

(b) The amount of the credit, setoff, reduction, or deduction; and

(c) A brief description of the factual basis for the credit, setoff, reduction, or deduction.

COMMENT:

Interrogatory #6 is not intended to address any reduction in the verdict that may arise from the application of General Statutes

§ 52-572h (regarding comparative negligence and apportionment) or General Statutes § 52-225a (regarding collateral sources,

as defined by General Statutes § 52-225b).

(7) Are you aware of any other insurance policy affording uninsured/underinsured motorist coverage,

to any plaintiff herein, that is primary to the coverage afforded by your policy?

(8) If so, for each such policy, state:

(a) The name and address of the insurer;

(b) The name and address of each named insured;

(c) The policy number;

(d) The limits of uninsured/underinsured motorist coverage under such policy; and

(e) The basis for your contention that it is primary to your policy.

(9) 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.

(10) As to each individual named in response to Interrogatory #9, state whether to your knowledge,

or the knowledge of your attorney, such individual has given any statement or statements as defined

in the Practice Book Sections 13-1 and 13-3 (b) concerning the subject matter of the Complaint in this

action. If the answer to this interrogatory is affirmative, state also:

(a) The name and address of the person giving the statement;

(b) The date on which the statement or statements were taken;

(c) The names and addresses of the person or people who took such statement(s);

(d) The name and address of any person present when such statement(s) was taken;

(e) Whether such statement(s) was written, made by recording device, or taken by a court reporter

or stenographer; and

(f) The name and address of each person having custody or a copy or copies of such statement(s).

(11) 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, 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.).

(12) 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 action 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 recording was obtained and the

person or persons of whom each such recording was made.

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).