Sample Requests for Admission in Auto Accident Case

Below are sample requests for admission in a car accident case.  These are pretty simple requests that should go out when you serve the complaint.  Getting the defendant to take positions from the very beginning of the case helps you box the defendant early into the positions they are going to take, often before they have spent much time thinking about the case. 

Another fun thing to is the police report and the statements made at the crash scene by the defendant or the text of the police report and see if defendant will deny them.  Often, they will deny the sky is blue and never amend those answers before trial.  If the defendant is taking ridiculous positions, this is a great way to underscore that with the jury. 

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.

Request No. 15. Plantiff suffered injuries in the crash.

Request No. 16. Defendant suffered injuries in the crash.

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

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