Example Slip and Fall Requests for Admission

Below are sample request for admission for a slip and fall case.

IN THE CIRCUIT COURT FOR TALBOT COUNTY, MARYLAND

RAYMOND MCKINNON
Plaintiff,
v. Case No.: _
________________
THE BEDFORD COUNTRY INN, LLC
Defendant

PLAINTIFF'S REQUESTS FOR ADMISSION TO DEFENDANT'S

TO: The Bedford Country Inn, LLC, Defendant

FROM: Raymond McKinnon, Plaintiff

The Plaintiff, Raymond McKinnon, by and through his attorneys, Miller & Zois, LLC, requests that Defendant, The Bedford Country Inn, LLC, admit or deny the following statements of fact. If objection is made, please state the reason for the objection.

REQUESTS FOR ADMISSIONS
    Motion to Strike
  1. Raymond McKinnon, is a resident of Montgomery County Maryland.
  2. The Bedford Country Inn, LLC manages the premises known as The Bedford Country Inn, LLC, located in or near Talbot County, Maryland.
  3. On or about May 17, 2017, Plaintiff was walking from a cottage toward the main building on premises owned, controlled, managed and maintained by The Bedford Country Inn, LLC, as identified in the Complaint.
  4. Plaintiff had no alternative means to get from the cottage to the main building.
  5. Plaintiff was caused to trip and fall due to an unsecured wooden railroad tie that The Oaks placed and allowed to remain along a walkway intended for pedestrian use.
  6. Raymond McKinnon did not in any way contribute to the fall alleged in the Complaint.
  7. Raymond McKinnon did not in any way assume the risk of the collision or his injuries.
  8. Raymond McKinnon was injured as a result of his fall.
  9. Raymond McKinnon had the right to walk from the cottage to the main building at the time of the occurrence.
  10. The Bedford Country Inn, LLC failed to keep post warnings about the condition of the walkway for pedestrian use.
  11. The Bedford Country Inn, LLC failed to maintain a well-lit pathway.
  12. The sole case of the accident complained of in the Complaint is due to the negligence of The Bedford Country Inn, LLC.
  13. Admit that The Bedford Country Inn, LLC, did not ask or any of its agents or employees, to remove the wooden railroad tie on May 17, 2017.
  14. Admit that at the time of the incident The Bedford Country Inn, LLC, were aware and knew that the wooden railroad tie was on the premises.
  15. Admit that the wooden railroad tie referenced in the Complaint was dangerous.
  16. Admit that you no longer have the wooden railroad tie.
  17. Admit that you knew had notice that the railroad tie would be evidence at trial in this lawsuit.
  18. Bellavista Properties, LLC owns the real property on which Plaintiff fell during the incident which is the subject of this lawsuit.
  19. Bellavista Properties, LLC owns the real property located at 25876 Royal Oak Road, Easton, Maryland 21601.
  20. On or about May 17, 2017, Plaintiff was walking from a cottage toward the main building on property that was maintained by The Bedford Country Inn, LLC, as identified in the Complaint.
  21. On or about May 17, 2017, Plaintiff was walking from a cottage toward the main building on property that was managed by The Bedford Country Inn, LLC, as identified in the Complaint.
  22. Plaintiff had no alternative means to get from the cottage to the main building on the evening of May 17, 2017 other than by using the path that he travelled.
  23. The wooden railroad tie pictured below presents a tripping hazard to pedestrians:
  24. The wooden railroad tie pictured below is lifted up off of the ground on the left end:
  25. Raymond McKinnon did not contribute to his slip and fall injury which is alleged in the Complaint.
  26. Raymond McKinnon did not assume the risk of the injuries he suffered on May 17, 2017.
  27. Raymond McKinnon was injured as a result of his fall on May 17, 2017.
  28. Raymond McKinnon had the right to walk from the cottage to the main building on the evening of May 17, 2017.
  29. Because of his fall on May 17, 2017, Raymond McKinnon had to get physical therapy.
  30. The Bedford Country Inn, LLC did not place warning signs on outside areas of the subject premises letting pedestrians known of things, if any, that they could trip over.
  31. Plaintiff fell, at least in part, due to a wooden railroad tie that was located along a walkway on the subject property. (See Request for Admission No. 23, above, to understand what a railroad tie is.)
  32. The Bedford Country Inn, LLC provided inadequate artificial lighting on the outside of the subject property.
  33. The Bedford Country Inn, LLC was at least partially at fault for causing Plaintiff's fall on May 17, 2017.
  34. When Raymond McKinnon fell on May 17, 2017, he suffered pain.
  35. The Bedford Country Inn, LLC, did not ask for any of its agents, contractors or employees, to remove any wooden railroad ties from the subject property in the one year preceding the incident which is the subject of this lawsuit. (See Request for Admission No. 23, above, to understand what a railroad tie is.)
  36. At or around 10:00 p.m. on May 17, 2017, Plaintiff tripped and fell on an outside area of the property located at 276 Westley Road, Easton, Maryland 21601.
  37. The Bedford Country Inn, LLC is liable for any of the injuries complained of in the Complaint.
  38. At the time of the incident, Bedford Country Inn, LLC knew that the subject property had a wooden railroad tie on it. (See Request for Admission No. 23 to understand what a railroad tie is.)
  39. At the time of the incident, Bedford Country Inn, LLC did not know that the subject property had any wooden railroad ties on it. (See Request for Admission No. 23 to understand what a railroad tie is.)
  40. The Bedford Country Inn, LLC did not do anything that it thinks was wrong or improper on May 17, 2017.
  41. Bedford Country Inn, LLC did not do anything that contributed to Raymond McKinnon's injuries which he suffered on May 17, 2017.
  42. Raymond McKinnon broke his leg when he fell on May 17, 2017.
Thoughts on These Requests for Admission

Premises Liability Requests for admission are underutilized in litigation and particularly underutilized in slip and fall cases. Every litigation treatise describes requests for admission as path to expedite and simplify litigation. This is the primary purpose of requests for admission.

But they can do so much more. You can use admission requests to dispose of interrogatories to give you more opportunities to ask real questions. You can also use RFAs to get defendants to commit to positions early in the litigation. It is not just useful admissions that can help you. Many defendants will deny the sky is blue. When you read those answers to the jury - answers that often contradict their own witnesses - the jury gets the clear impression that the defense is not credible.

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