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Personal Injury Requests for Admission to Plaintiff

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


DEFINITIONS

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

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



Requests for Admission
   1. Admit that YOU were employed at the time of the INCIDENT.

   2. Admit that YOU have previously injured YOUR _____________ [Instructions: Insert
      relevant body part].

   3. Admit that YOU did not suffer any loss of earnings due to the INCIDENT.

   4. Admit that YOU did not suffer any injury because of the INCIDENT.

   5. Admit that YOU take prescription medications.

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

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

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

   9. Admit that YOU did not seek adequate medical care after the INCIDENT.

   10. Admit that YOU contributed to cause YOUR alleged injuries.

   11. Admit that the defendant does not owe YOU a duty of care.

   12. Admit that there is no relationship between YOU and the defendant.

   13. Admit that defendant acted reasonably under the circumstances at the time of the
       INCIDENT.
    14. Admit that defendant took reasonable steps to avoid the INCIDENT, which caused
        YOUR alleged injuries.

    15. Admit that YOUR alleged injury would have occurred despite _____________
        [Instructions: Set forth Plaintiff’s allegations regarding defendant’s breach of duty
        of care].

    16. Admit that defendant did not materially increase the risk of harm to Plaintiff.

    17. Admit that defendant could not reasonably foresee the alleged injury occurring to
        Plaintiff.

    18. Admit that YOU suffered no harm.

    19. Admit that YOU suffered no emotional distress.

    20. Admit that defendant did not intentionally cause any injury to YOU.

    21. Admit that YOU assumed the risk of YOUR injuries.

    22. Admit that YOUR case is barred by the statute of limitations.

    23. Admit that YOU were contributorily negligent.

    24. Admit that YOU did not sustain injuries as a result of the INCIDENT.

    25. Admit that YOU have insurance covering YOUR alleged damages in this action.

    26. Admit the treatment from _____________ [Instructions: Set forth name of treating
        physician or medical facility] was medically unnecessary to treat YOUR injuries and it
        was unrelated to the Incident.

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


Dated: ________________ [Instructions: Insert date]

________________ [Instructions: Set forth name]

Attorneys for Defendant

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

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