IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
Ernesto Fair- Plaintiff v Diana Beatrix Salvador- Defendant |
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CASE NO.: 05-C-00-1234 |
PLAINTIFF’S SECOND REQUEST FOR ADMISSIONS
Plaintiff, Ernesto Fair, by and through his attorneys, Ronald V. Miller, Jr., and Miller & Zois, LLC, requests that Defendant, Diana Beatrix Salvador, admit or deny the following statements of law. If objection is made, please state the reason for the objection. Please specifically deny the matter or set forth in detail the reasons why the answering party cannot truthfully admit or deny the matter. Also, please note that the term "car crash" refers to the motor vehicle collision which is the subject of this lawsuit and which occurred on or about March 17, 2002.
REQUESTS FOR ADMISSION
1. The only witnesses to the accident were Plaintiff, Defendant
and an unidentified man who let Plaintiff use his cell phone at
the scene of the accident.
2. You were traveling too fast for the weather conditions
3. Plaintiff injured his neck, chest, and right knee in the accident.
4. Plaintiff’s right knee injuries are permanent.
5. As of the date of this pleading, at work, Plaintiff needs to
use the left leg to compensate for the injured right knee.
6. As of the date of this pleading, due to the increased demand
on Plaintiff's left leg, he has pain in his left knee.
7. As of the date of this pleading, Plaintiff experiences pain
and difficulty walking up steps.
8. As of the date of this pleading, Plaintiff has intermittent
pain and swelling in my right knee.
9. As of the date of this pleading, extended driving time is painful
to Plaintiff's knee.
10. Plaintiff was more susceptible to the knee injury that he
suffered in the car crash.
11. Plaintiff's knee injury in the car crash aggravated a pre-existing
condition.
12. Plaintiff incurred over $23,500.00 in medical bills after
the car crash.
13. Defendant apologized to Plaintiff after the accident.
14. As she approached a curve on Mt. Pleasant Road on February
10, 2003, Defendant was traveling at a speed where she felt compelled
to apply her brakes.
15. Defendant was aware that applying her brakes on a road where
ice existed could lead her to lose control of her vehicle.
16. Defendant had a duty to consider the condition of the road
in determining the speed at which she was traveling on February
10, 2003.
17. Defendant lost control of her vehicle on February 10, 2003
that led to the car crash because she chose to apply her brakes
on an icy road.
Respectfully
submitted,
MILLER & ZOIS, LLC
Ronald
V. Miller, Jr.
Empire
Towers, Suite 615
7310
Ritchie Highway
Glen
Burnie, Maryland 21061
(410)553-6000
(410)760-8922
(Fax)
Attorney
for the Plaintiff
Certificate of Service
I hereby certify that a copy of the foregoing Second Request for Admissions was sent via U.S. Mail, first-class, postage prepaid, this 26th day of July, 2004, to:
John J. Schneider, Esq.
Staff Counsel
Allstate Insurance Company
10 N. Calvert Street, Suite 444
Baltimore, Maryland 21202
Counsel for Defendant
Ronald V. Miller, Jr.
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