Fill and Sign the First Set of Requests for Admissions Propounded by Plaintiff to Defendant Form

IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________       ) )       ) Petitioner/Plaintiff, ) ) ) NO.       Vs. ) )       ) Respondent/Defendant ) ) FIRST SET OF REQUESTS FOR ADMISSIONS PROPOUNDED BY PLAINTIFF TO DEFENDANT The Plaintiff ___________________ propounds this his First Set of Requests for Admissions pursuant to Rule ____ of the ___________________ Rules of Civil procedure, requesting that the Defendant admit or deny the truthfulness of said requests within ________ (___) days of service hereof. DEFINITIONS The term “accident”, as used occurrence described in the complaint herein means the ___________________. REQUESTS FOR ADMISSIONS Request No. 1: That Defendant was the operator of the ___________________ automobile that collided with the rear of Plaintiff's automobile on the ____ day of ____________, 20____. - 1 - Request No. 2: That Defendant was the owner of the ___________________ automobile that collided with the rear of Plaintiff's automobile on the ____ day of ____________, 20____. Request No. 3: That on the ____ day of ____________, 20____, Defendant, ____________ drove into the rear of Plaintiff’s his automobile. Request No. 4: That Defendant drove his automobile into the rear of Plaintiff's automobile. Request No. 5: That the front of the automobile collided with the rear of the automobile. Request No. 6: That Plaintiff's automobile was stopped at the time of the accident. Request No. 7: That Plaintiff's automobile was stopped when Defendant drove his automobile into the rear of plaintiff’s automobile. Request No. 8: That at the time of the accident failed to have his automobile under proper control. Request No. 9: That at the time of the accident Defendant failed to maintain a proper lookout. Request No. 10: That at the time of the accident Defendant failed to maintain a reasonable distance behind Plaintiff’s automobile so as to avoid colliding with Plaintiff’s automobile. Request No. 11: That at the time of the accident Defendant was negligent as a matter of law in violating Section ________ of the __________ Code Annotated. Request No. 12: That Defendant was negligent in colliding with the rear of Plaintiff's vehicle. Request No. 13: That the accident was proximately caused by Defendant’s failure to keep his vehicle under control, keep a proper look - out ahead, and to drive at a speed and - 2 - sufficient distance behind Plaintiff's automobile to avoid colliding with Plaintiff's automobile. Request No. 14: That at the time of the accident made the subject of this suit, Plaintiff’s automobile was stopped at the intersection of Highway ___ and ____________ Road. Request No. 15: That at the time of the accident the brake lights on Plaintiff's automobile were functioning. Request No. 16: That at the time of the accident Defendant negligently drove his automobile into the rear of Plaintiff’s automobile. Request No. 17: That Defendant proximately caused the accident. Respectfully submitted, Dated: Name: Title: Address: Address: City, State, Zip: Phone: Fax: E-Mail: Attorney No.: - 3 - CERTIFICATE OF SERVICE I, ______________________________, do hereby certify that I have this day mailed, U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing to __________________________________, at the following address; ___________________________________________________________________ THIS the ____ day of _____________, 20____. _________________________________ - 4 -