Tricks of the Trade
By Private Investigator Michael T. O'Rourke

Question: I am a paralegal in a law firm specializing in plaintiff’s personal injury cases. Our client was involved in a collision on the Delaware Memorial Bridge as she passed through the toll booth. The defendant, in this case, is a New Jersey resident. He was taken into custody by the Delaware River Bay Authority Police immediately after the police officer checked his license.

How do I find out more information about the defendant?

Answer: Start with the drivers license number. A New Jersey drivers license number is 15 digits. A letter, followed by 14 numbers. There are three sets of five digits each, and each set is separated by a single space.

The letter digit is the first letter of the licensee’s last name. The next four digits represent the next four letters in the licensee’s last name. They are in an unpublished DMV code. Every person with the same last name will have the same first five digit set in New Jersey.

The next five-digit set is an unpublished DMV code representing the middle initial and other DMV administrative data. The first two digits of the last five-digit set indicate the licensee’s month and year of birth. Hence, the first two digits will always be 01 through 12, if the licensee is a male, and 51 through 62 if the licensee is female.

NJ DMV adds 50 to the birth months to represent a female gender. The third, and fourth, digits of the final five-digit set represent the year of birth (the same for both gender). The final digit is eye color. 2 is brown, 4 is blue, 5 is hazel, and 6 is green.

Contact NJ DMV in Trenton, N.J. and obtain a certified copy of the defendant’s driving history, and vehicles by name. Also obtain vehicle registration information on the vehicle the defendant was operating at the time of loss.

The driving history will reveal a last known address, and date of birth. The vehicle information will provide you ownership information and the name of the insurance company.

You now have the names, and addresses of all defendants -- the driver, the vehicle owner (negligent entrustment), and the insurance company.

Use your favorite investigative resource (you can call me) to verify the addresses, and obtain other materials relevant to your case. It will be especially interesting to conduct an inquiry regarding criminal records involving the defendant.

Why did the Police Officer take the defendant into custody? Review the Uniform Traffic Collision Report.

Was there a DUI involved? Was the defendant charged with a moving violation? Any witnesses listed on the Report by the Police Officer?

If the accident was especially severe, the fatal accident reconstruction team will also provide a report. This report is conducted on some non-fatal accidents.

Secure recorded statements of all witnesses (driver, passengers, toll collectors, police officer, EMT’s, Fire/Rescue personnel) for future use.

Was either of the vehicles towed? Don’t forget to contact the tow operator. You can’t imagine the things said to a tow truck driver.

Obtain photographs of the accident scene and the vehicles involved in the collision.

Ask the investigator to provide asset/liability information with their report. This will help the attorney decide if they should go after policy limits in extreme cases, or in an asset rich environment, take another approach.

Det. Michael T. O'Rourke is a Member of the National Association of Investigative Specialists, The National Association of Professional Process Servers, and sustaining member of the Delaware Paralegal Association. He is also a Court Certified Special Process Server, and a Licensed Private Investigator in DE and PA. Michael specializes in Insurance Defense and Criminal Defense. He invites your questions to:

Loss Solutions, Inc.
824 N. Market Street,
Suite 425, P.O. Box 368,
Wilmington DE
19899-0368.
(302) 427-3600.

Or you may e-mail him at DeIrish5@aol.com.

Previous Tricks of the Trade from Michael T. O'Rourke:

October 20, 2002
September 16, 2002
August 25, 2002
May 28, 2002
March 25, 2002
February 25, 2002
January 17, 2002
November 26, 2001
October 23, 2001
September 25, 2001