Personal Injury Requests for Admission to Defendant

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					This Personal Injury Requests for Admission to Defendant form sets forth many of the
necessary admissions that must be sought from a defendant in a personal injury case.
Requests for admissions should be sent early in the discovery process in order to
eliminate issues in the case that are undisputed. The defendant's admissions can
assist the plaintiff in narrowing the scope of the case, which will allow the plaintiff to
focus on the most crucial issues. This document can be customized to fit the user's
unique situation. This should be used by plaintiffs or their attorneys when conducting
discovery in a personal injury case.
                     Personal Injury Requests for Admission to Defendant


DEFINITIONS

      1. The term “YOU” and “YOUR” refers to the responding party, Defendant
________________ [Instructions: Insert name of Defendant].

       2. The term “INCIDENT” refers to Plaintiff’s alleged injury at ________________
[Instructions: Insert location] on ________________ [Instructions: Insert date] as set forth in
the Complaint.



Requests for Admission


   1. Admit that YOU take prescription medications.

   2. Admit that YOU were under the influence of prescription medications at the time of the
      INCIDENT.

   3. Admit that YOU have used a narcotic substance, including, but not limited to,
      methamphetamine, cocaine and/or marijuana.

   4. Admit that at the time of the INCIDENT, YOU were under the influence of a narcotic
      substance.

   5. Admit that Plaintiff sought adequate medical care after the INCIDENT.

   6. Admit that YOU contributed to cause Plaintiff’s injuries.

   7. Admit that YOU owe Plaintiff a duty of care due to YOUR position as _____________
      [Instructions: Set forth position].

   8. Admit that YOU acted unreasonably under the circumstances at the time of the
      INCIDENT.

   9. Admit that YOU did not take reasonable steps to avoid the INCIDENT, which caused
      Plaintiff’s injuries.

   10. Admit that Plaintiff’s injury would not have occurred without YOUR actions at the time
       of the INCIDENT.

   11. Admit that YOU materially increased the risk of harm to Plaintiff.
    12. Admit that YOU could reasonably foresee the injury, _____________ [Instructions: Set
        forth description of injury] occurring to Plaintiff.

    13. Admit that Plaintiff suffered harm as a result of the INCIDENT.

    14. Admit that Plaintiff suffered emotional distress as a result of the INCIDENT.

    15. Admit that Plaintiff suffered damages as a result of the INCIDENT.

    16. Admit YOU intentionally injured Plaintiff.

    17. Admit that YOU were personally served with the Summons and Complaint in this action.

    18. Admit that there is no basis for YOU to claim that the Court lacks jurisdiction over YOU.

    19. Admit that there is no evidence to support the contention that Plaintiff assumed the risk
        of Plaintiff’s injuries.

    20. Admit that Plaintiff’s case is not barred by the statute of limitations.

    21. Admit that Plaintiff was not contributorily negligent.

    22. Admit the Plaintiff sustained injuries as a result of the INCIDENT.

    23. Admit that YOU have insurance covering YOUR liability in this action.

    24. Admit the treatment from _____________ [Instructions: Set forth name of treating
        physician or medical facility] was medically necessary to treat Plaintiff’s injuries and
        related to the INCIDENT.

    25. Admit that the bill for services from ____________ [Instructions: Set forth name of
        treating physician or medical facility] was reasonable.

    26. Admit YOUR insurance company offered _____________ [Instructions: Set forth
        amount of offer] to settle this matter.




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Dated: ________________ [Instructions: Insert date]



________________ [Instructions: Set forth name]

Attorneys for Plaintiff



[Comments: User should attach a proof of service with this request for production of
documents]




© Copyright 2012 Docstoc Inc.                                                          4

				
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Description: This Personal Injury Requests for Admission to Defendant form sets forth many of the necessary admissions that must be sought from a defendant in a personal injury case. Requests for admissions should be sent early in the discovery process in order to eliminate issues in the case that are undisputed. The defendant's admissions can assist the plaintiff in narrowing the scope of the case, which will allow the plaintiff to focus on the most crucial issues. This document can be customized to fit the user's unique situation. This should be used by plaintiffs or their attorneys when conducting discovery in a personal injury case.