i ______________________ REQUEST FOR ADMISSIONS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST FOR ADMISSIONS WHAT IS THE DOCUMENT? Written discovery device whereby one party can require another party to admit or deny relevant facts and/or authenticate or admit the genuineness of documents. WHAT ARE THE APPLICABLE STATE/LOCAL COURT RULES? 1. CCP Section 2033 SPECIAL RULES OR OTHER REQUIREMENTS 1. May only be served on other parties 2. Plaintiff must wait 10 days after the defendant is served with the complaint or appears in the action before serving requests for admissions. Defendant can serve requests for admissions at any time. 3. No preface, instructions or subparts (including compound, conjunctive or disjunctive questions) permitted in requests for admissions. 4. No party may serve without leave of Court more than 35 requests for admissions [EXCEPTIONS: Requests to admit authenticity of attached documents do not count against the 35 limit; Party may serve additional requests for admissions if accompanied by declaration pursuant to CCP § 2033(c)(3)]. 5. Party serving requests keeps custody of originals and serves copies on the responding party and on all other parties who have appeared in the action. Original responses must be verified ii ______________________ REQUEST FOR ADMISSIONS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 by the responding party and served within 30 days if the requests were personally served and 35 days if the requests were mail served. 6. Parties may stipulate to extend the deadline to respond to requests for admissions so long as extension in confirmed in a writing that specifies the new response date.1 ______________________ REQUEST FOR ADMISSIONS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STEIN & ASSOCIATES Michael D. Stein (SBN 132540) 5235 West Allen Street Suite 200 Los Angeles, CA 90067 Tel: (213) 555-0994 Fax: (213) 555-0995 Attorneys for Plaintiff SCOTT ALAN WOODWARD SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES SCOTT ALAN WOODWARD, Plaintiff, vs. B-2 VIDEO INCORPORATED, a California corporation; and DOES 1 through 20 inclusive, Defendants. ) ) ) ) )))))) ))) )) ) ) ) ) )) Case No.: ASSIGNED FOR ALL PURPOSES TO JUDGE JOHN SMITH Department 27 PLAINTIFF SCOTT ALAN WOODWARD’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT B-2 VIDEO INCORPORATED ) PROPOUNDING PARTY: Plaintiff SCOTT ALAN WOODWARD RESPONDING PARTY: Defendant B-2 VIDEO INCORPORATED SET NO.: One 2 ______________________ REQUEST FOR ADMISSIONS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Pursuant to Code of Civil Procedure Section 2033, plaintiff Scott Alan Woodward (“Plaintiff”) requests that defendant B-2 Video Incorporated (“B-2”) respond under oath to the following requests within 30 days of service hereof. REQUEST NO. 1: Admit YOU (For the purpose of these requests for admissions, the term “YOU” shall mean defendant B-2 Video Incorporated, its divisions, subsidiaries, affiliated entities, predecessors and successors in interest, and all officers, servants, employees, agents, representatives, persons or entities acting on its behalf or on behalf of any division, subsidiary or affiliated entity, whether individually or collectively) did not implement a reduction in force policy because of economic conditions in the 2002 calendar year. REQUEST NO. 2: Admit that the only employees terminated from the unit in which PLAINTIFF (For the purpose of these requests for admissions, the term “PLAINTIFF” shall mean Scott Alan Woodward) worked were PLAINTIFF and Greg Jones. ///////////////3 ______________________ REQUEST FOR ADMISSIONS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST NO. 3: Admit that the May 9, 2002 memorandum to PLAINTIFF attached hereto as Exhibit “A” is authentic. DATED: March 31, 2004 STEIN & ASSOCIATES By: _________________________________ Michael D. Stein Attorneys for Plaintiff SCOTT ALAN WOODWARD 4 ______________________ REQUEST FOR ADMISSIONS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA ) ) ss: COUNTY OF LOS ANGELES ) I am employed in the County of Los Angeles, State of California. I am over the age of 18 years and am not a party to the within action. My business address is 5235 West Allen Street Suite 200, Los Angeles, CA 90067. On March 31, 2004, I served the foregoing documents described as PLAINTIFF SCOTT ALAN WOODWARD’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT B-2 VIDEO INCORPORATED on the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Peter Crawford, Esq. 27255 Van Buren Road Torrance, California 93627 ___ BY MAIL I deposited such envelope into the Firm’s office mail at Los Angeles, California. I am readily familiar with the Firm’s practice of collection and processing correspondence for mailing. Under that practice, in the ordinary course of business, the mail is affixed with postage thereon fully prepaid and deposited with the U.S. Postal Service in Los Angeles, California on the same day. I am aware that on motion of a party served, service is presumed invalid if the postal cancellation date or the postage meter date is more than one (1) day after the date of deposit for mailing in this affidavit. ___ BY PERSONAL SERVICE I hand delivered such envelope to the offices of the addressee(s) listed above. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed March 31, 2004 at Los Angeles, California. _____________________________ Harriet Evans