N.C.P.I.—Motor Vehicle 100.44

Members of the Jury, at an earlier time the [plaintiff] [defendant]

[(name any other party that addressed interrogatories)] submitted questions

to the [plaintiff][defendant] [(name any other party that received

interrogatories)]. These questions are called interrogatories. The [plaintiff]

[defendant] [(name any other party that received interrogatories)] was

required to answer the interrogatories under oath. The [plaintiff] [defendant]

[(name any other party that addressed interrogatories)] has introduced some

of the questions and the answers into evidence as the [plaintiff's]

[defendant's] [(name any other party)] exhibit number. ____

You may treat the answers like admissions of the [plaintiff] [defendant]

[(name any other party that received interrogatories)]2

Not only may you consider the answers as evidence, but you may give

the answers such weight as you determine is appropriate in light of any

other evidence offered by the [plaintiff] [defendant] [(name any other

party)] as to mistake, excusable neglect or some other justifiable error in

these answers.

[You are not, however, to consider the answers of the [plaintiff

(name)] [defendant (name)] [(name any other party that received

interrogatories)] as evidence against the [(name another appropriate

party)].]3

Also, members of the jury, the (name party introducing the interrogatory

answers) is not bound by those answers. In other words, the (name party

introducing the interrogatory answers) may offer other evidence to contradict,

explain or challenge the answers given by the (name party answering the

interrogatories).