Sample Requests for Admission in Auto Accident Case

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

KEVIN STERN - Plaintiff
v
STATE FARM, et al. - Defendants,

CASE NO. 24-C-04-006577 OT

Plaintiff’s Request for Admissions of Facts and Genuineness of Documents to Defendant

The Plaintiff, Kevin Stern, by his undersigned attorneys, pursuant to Maryland Rule 2-424, requests that the Defendant State Farm admit or deny, within 30 days of the date of service of the request that:

Uninsured Motorist Cases

Request No. 1. Plaintiff was insured with State Farm 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 State Farm, State Farm 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 State Farm, 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 State Farm 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 State Farm, 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 State Farm issued (State Farm 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.
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (Fax)
Attorney for the Plaintiff

Contact Us For a Free Consultation

If you are hurt in a serious accident or are the victim of medical malpractice, contact our team of lawyers to discuss your case.
Call us now for help at (800) 553-8082

You can also get a FREE no obligation on-line consultation.

Client Reviews

  • They quite literally worked as hard as if not harder than the doctors to save our lives.
    ★★★★★
  • Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for.
    ★★★★★
  • Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone!
    ★★★★★
  • The last case I referred to them settled for $1.2 million.
    ★★★★★
  • I am so grateful that I was lucky to pick Miller & Zois.
    ★★★★★
  • The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable.
    ★★★★★
  • The case settled and I got a lot more money than I expected. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement.
    ★★★★★
  • Miller and Zois is the best firm in the state of Maryland, and without their support, understanding, and just being there when I needed encouragement, I truly do not know how I would have succeeded without them.
    ★★★★★

Contact Us

Free Consultation (800) 553-8082 Call 24/7