IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI
PLAINTIFF
VS. CAUSE NO.
, Individually,
and DEFENDANT
DEFENDANT'S RESPONSE TO
PLAINTIFF'S REQUESTS FOR ADMISSIONS
COMES NOW the Defendant and files this his/her Response to Plaintiff's
Requests for Admissions and in support thereof would show as follows:
By agreement of the parties, the time for responding to said Requests is now due on
, , and Defendant responds as follows:
REQUEST NO. 1: Admit or deny that prior to , , was a
corporation, doing business in Mississippi, and in good standing with the Mississippi Secretary
of State's office.
RESPONSE:
REQUEST NO.2: Admit or deny that was a Mississippi corporation in good
standing between the periods of , through , .
RESPONSE:
REQUEST NO. 3: Admit or deny that you held the position and functioned in the role of
for between , and , .
RESPONSE:
REQUEST NO. 4: Admit or deny that on , , the Mississippi Secretary
of State administratively dissolved .
RESPONSE:
REQUEST NO.5: Admit or deny that you executed a Bill of Sale on
, which sold, conveyed and warranted to , an undivided ( )
interest in certain property situated in County, Mississippi which was referenced as
Exhibit A" to the Bill of Sale and that Exhibit "A" was entitled “ . Equipment Inventory
List".
RESPONSE:
REQUEST NO.6: Admit or deny that the equipment and inventory referenced in Request
No. 5 was equipment and inventory, which was owned and controlled by as of
, .
RESPONSE:
REQUEST NO. 7: Admit or deny that you were not involved in any other
business, partnership/corporation or the like other than your involvement with during the
years through .
RESPONSE:
REQUEST NO. 8: Admit or deny that prior to , , was a former
of denies that corporation, operation as .
RESPONSE:
REQUEST NO. 9: Admit or deny that the Bill of Sale executed by you on
, effectively transferred to Plaintiff the former ( ) interest owned by
prior to his/her withdrawal/separation from .
RESPONSE:
REQUEST NO. 10: Admit or deny that you negotiated a $ check made payable to
you by Plaintiff.
RESPONSE:
REQUEST NO. 11: Admit or deny that during the years of and/or , you
established a bank account separate and apart from the account maintained on behalf of .
RESPONSE:
REQUEST NO. 12: Admit or deny that you deposited corporate and/or partnership funds
in the account(s) referenced in Request for Admission No. 11.
RESPONSE:
REQUEST NO. 13: Admit or deny that you currently retain certain items of equipment
which were originally placed at your disposal for business use by the Plaintiff.
RESPONSE:
REQUEST NO. 14: Admit or deny that following 's departure from that you
were the sole remaining officer of the corporation.
RESPONSE:
REQUEST NO. 15: Admit or deny that subsequent to 's departure from you
had the sole responsibility for maintaining all corporate records and for maintaining and
controlling its corporate assets on behalf of .
RESPONSE:
REQUEST NO. 16: Admit or deny that is currently exercising control and
possession over items of equipment originally placed at your disposal for business use by the
Plaintiff.
RESPONSE:
REQUEST NO. 17: For all equipment relevant to Request No. 15, admit or deny that
you have sold such equipment subsequent to Plaintiff's disassociation with you.
RESPONSE:
REQUEST NO. 18: Admit or deny that never issued any stock, common or
otherwise, to Plaintiff.
RESPONSE:
REQUEST NO. 19: Admit or deny that was never elected as an officer of ,
or elected to a director's position in the corporation.
RESPONSE:
REQUEST NO. 20: Admit or deny that you previously valued and/or your
partnership with Plaintiff at $ .
RESPONSE:
Any further response concerning settlement negotiations are not admissible under Rule
408 of the Mississippi Rules of Civil Procedure.
Respectfully submitted,
_______________________________________
Attorney for
Of counsel:
Telephone:
MSB #
Attorney for
STATE OF MISSISSIPPI
COUNTY OF
Personally came and appeared before me, the undersigned authority in and for the
jurisdiction aforesaid, , who, being by me first duly sworn, stated on his/her oath that the
matters and facts set forth in the above and foregoing Defendant's Response to Plaintiff's
Request for Admissions are true and correct as therein stated.
SWORN TO AND SUBSCRIBED BEFORE , this the day of ,
20 .
__________________________________
NOTARY PUBLIC
My Commission Expires:
CERTIFICATE OF SERVICE
I, do hereby certify that I have this day mailed a true and correct copy of the
above and foregoing DEFENDANT'S RESPONSE TO PLAINTIFF'S REQUESTS FOR
ADMISSIONS to the following counsel of record:
Dated this day of , 2 .
_______________________________________
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