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Fill and Sign the Plaintiffs Request for Admissions Mississippi Form

Fill and Sign the Plaintiffs Request for Admissions Mississippi Form

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IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. CAUSE NO.             DEFENDANT PLAINTIFF'S REOUEST FOR ADMISSIONS COMES NOW       , by and through his/her counsel, and files this his/her First Request for Admissions to the defendant, to be answered in the time and manner required by the rules of procedures as follows: 1. Please admit that prior to       ,       , the plaintiff       was the owner of       , serial number       . 2. Please admit that       issued a policy of insurance on this trailer effective       ,       which was policy number       . 3. Please admit that at all times in from       ,       to the date the trailer was destroyed by a tornado       dba       was the agent of       as defined by Mississippi law in regard to this policy and its successors. 4. Please admit that in       ,       or his/her office was informed the home address of       was       ,       , Mississippi and that the address of the trailer was       ,       , Mississippi. 5. Please admit that your agent       was informed that       did not live in the trailer, but that in       ,       his/her son/daughter       lived in the trailer. 6. Please admit that the premiums for the policy described in Request No.       were paid on a timely basis. 7. Please admit that the policy described in Request No.       was renewed for the policy period       ,       to       ,       . 8. Please admit that a cancellation notice for this policy was mailed on       ,       to       at       ,       , Mississippi. 9. Please admit that a reinstatement notice of this policy was mailed to       at       ,       , Mississippi by       on       ,       . 10. Please admit that on       ,             changed the address of the named insured on this policy to       ,       ,       , Mississippi. 11. Please admit that       never requested that       change the policy to reflect the named insured was       at an address of       ,       , Mississippi. 12. Please admit that       has never lived at       ,       , Mississippi. 13. Please admit that at all times between       ,       and the present       has lived at             , Mississippi. 14. Please admit that       never sent any notice to       at       ,       , Mississippi that it had changed the address of the named insured on this policy to       ,       , Mississippi. 15. Please admit that the notice       or its agent sent to       of the change of address was returned to       marked "return to sender." 16. Please admit that       sent a notice of cancellation to       dated       ,       at the address of       ,       , Mississippi. 17. Please admit that       never received the notice of cancellation dated       ,       referred to in Request No.       . 18. Please admit that       never knew this coverage had been cancelled until after the loss of the trailer by tornado damage. 19. Please admit that your agent       was informed in       ,       that       had purchased this trailer from       . 20. Please admit that your agent       was informed in       ,       that       was to take over the coverage on the trailer and that       was to be named as a lien holder on the policy. 21. Please admit that your agent       was informed in       ,       that       was financing the purchase of the trailer for       and that       owed       money for the purchase of the trailer. 22. Please admit that your agent       was informed in       ,       that       was to be the insured on the policy at an address of       ,       , Mississippi and       was to be a lien holder with an address of       ,       , Mississippi. 23. Please admit that your agent       by error continued to list       as the insured and in error changed the address on the policy for information to be sent to       . This the       day of             . Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for       CERTIFICATE OF SERVICE I,       , attorney for the plaintiff, do hereby certify that I have this day mailed a true and correct copy of the above to counsel for the defendant at his usual mailing address. This the       day of             . ______________________________      

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