Plaintiff’s Second Request for Admissions

Below are a follow-up set of request for admission designed to help set you up trial by putting the defendants in an untenable position: either admitting something that helps your case which they are loathe to do or denying something which you can use against them at trial because it underscores how silly and disingenuous their defense is.  

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

Ernesto Fair- Plaintiff
v
Cindy Beatrix Salvador- Defendant

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,  Cindy 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, 2015.

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. (Note: this is a great request for admission to ask.  The reflex is to deny everything. You can make a defendant look pretty silly denying an obvious injury at trial and it underscores what may be a trial theme: the refusal to take responsibility for ANYTHING.) 
  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 in Pasadena, Maryland on February 10, 2015, 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, 2015.
  17. Defendant lost control of her vehicle on February 10, 2015 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.
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(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, 2015, 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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