IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
KEVIN STEVENS - Plaintiff v DAVID MANNING, et al. - Defendants, |
* * * * * | CASE
NO. 24-C-04-006577 OT |
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PLAINTIFF’S REQUEST FOR ADMISSIONS
OF FACTS
AND GENUINENESS OF DOCUMENTS TO DEFENDANT
The Plaintiff, Kevin Stevens, by his undersigned attorneys, pursuant to Maryland Rule 2-424, requests that the Defendant GEICO admit or deny, within 30 days of the date of service of the request that:
Request No. 1. Plaintiff was insured with GEICO at the time of the car crash (see Plaintiff’s Interrogatories for definition of “car crash”).
Request No. 2. Plaintiff maintained uninsured motorist coverage at the time of the car crash.
Request No. 3. Because Plaintiff maintained uninsured motorist coverage with GEICO, GEICO has a contractual obligation to pay Plaintiff the damages he would have or will recover at trial against Mr. Manning, had Mr. Manning had $300,000 in coverage for this car crash.
Request No. 4. The only policy applicable to this case is Policy No. 0272802460101017, issued by GEICO, with liability limits of $300,000.00 per person.
Request No. 5. There was no umbrella or excess insurance policy applicable to this car crash other than Policy No. 0272802460101017, issued by GEICO with liability limits of $300,000.00 per person at the time of the collision.
Request No. 6. Defendant Manning had no other auto insurance policy for any other vehicles at the time of the car crash.
Request No. 7. Defendant Manning was not carrying out any duties for an employer at the time of the collision.
Request No. 8. Defendant Manning did not reside with anyone who had a policy of automobile insurance other than Policy No. 0 0272802460101017, issued by GEICO, with liability limits of $300,000 per person at the time of the car crash.
Request No. 9. There was no commercial automobile liability insurance that would cover this car crash.
Request No. 10. You have no evidence that any other policy of insurance covers besides the one that GEICO issued (GEICO Policy # 0272802460101017).
Request No. 11. There was no umbrella or excess insurance policy for this incident.
Request No. 12. Defendant Manning was not a lessee with insurance coverage through any lessor at the time of the collision.
Request No. 13. Defendant Manning’s negligence caused the car crash.
Request No. 14. The personal injuries suffered by Plaintiff are the result of Defendant Manning’s negligence.
Respectfully submitted,
MILLER & ZOIS, LLC
Ronald V. Miller, Jr.
Empire Towers, Suite 1001
7310 Ritchie Highway
Glen Burnie, Maryland 21061
(410)553-6000
(410)760-8922 (Fax)
Attorney for the Plaintiff
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