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Sample Plaintiff Requests for Admissions to Defendant

{LAW FIRM NAME}
{Address}
{City}, {State} {ZIP}
{Telephone:}
{Facsimile: }

{Lawyer Name (Bar No.)}
Email: {}

Attorney for Plaintiff

In the Superior Court of the state of Arizona
In and for the County of Maricopa

[],

Plaintiff,

v.

[],

Defendants.

Case No.: ____________________________

 

PLAINTIFF’S INITIAL RULE 26.1 DISCLOSURE STATEMENT

 

 

Plaintiff, by and through undersigned counsel and pursuant to Rule 36, Arizona Rules of Civil Procedure, requests that the Defendant answer, under oath and in writing within thirty (30) days after service, the following Request for Admissions:

INSTRUCTIONS

Each of the matters of which an admission is requested is admitted unless the Defendant to whom this Request is directed serves upon the party requesting the admission, within the appropriate time period, a written answer or objection addressed to the mater, signed by the party or by his/her attorney. If objection is made, the reasons therefore shall be stated. The answer shall specifically deny the matter or set forth in detail the reasons why the answering party cannot truthfully admit or deny the matter. A denial shall fairly meet the substance of the requested admission, and when good faith requires that a party qualify his/her answer or deny only a part of the matter of which an admission is requested, he shall specify so much of it as true and qualify or deny the remainder. An answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless he/she states that he/she has made reasonable inquiry and that the information known to or readily obtainable by him is insufficient to enable him to admit or deny. A party who considers that a matter of which an admission had been requested present a genuine issue for trial, may not, on that ground alone, object to the Request.

The answers to these requests shall include knowledge of the parties to whom this Request is directed, their attorneys, all agents, servants, representatives, investigators and others who may have obtained information on behalf of those parties or their attorneys.

Each party to whom this Request is directed, is required to supplement, in the time period allowed, his/her response with respect to any question directly addressed to the identity and location persons having knowledge of discoverable matters and the identity of each person expected to testify and the substance of his/her testimony. The party to whom this Request is directed is required to amend, in the time period allowed, a prior response if he/she obtains information the basis of which he/she knows that the response was incorrect when he/she knows that the response, through correct when made, is no longer true and the circumstances are such that a failure to amend a response is in substance a knowing concealment. When an individual Requests calls for an answer, which includes more than one part, each part of the answer should be clearly set out so that it is understandable.

REQUEST FOR ADMISSIONS

REQUEST NO 1:   Admit that [Insurance Company] insured you on the date you had the accident with Plaintiff on [].

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 2:  Admit that on [] you were traveling on [] near the street/intersection of [] on [].

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 3: Admit that you caused a collision with the side of Plaintiff’s vehicle.

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 4:  Admit that you are 100% liable with respect to causing the collision.

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 5:  Admit that your actions are the sole cause of the subject collision.

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 6:  Admit that at the time of the subject collision, you were using your cell phone.

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 7:  Admit that within 15 minutes of the subject collision, you were using your cell phone.

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 8:  Admit that at the time of the subject collision, you were texting on your cell phone.

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 9:  Admit that within 15 minutes of the subject collision, you were texting on your cell phone.

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 10: Admit that you were driving under the influence of alcohol at the time of the subject collision.

____ Admit               ____ Deny

If your response is a denial, please explain.

REQUEST NO. 11: Admit that you were driving under the influence of drugs at the time of the subject collision.

____ Admit               ____ Deny

If your response is a denial, please explain.

DATED this ____ day of _____________, _____.

 

 

 

{law firm name}

{NAME OF ATTORNEY}

{Law Firm Address}

{City} {Arizona}, {Zip}

Attorney for Plaintiff

 

 

ORIGINAL of the foregoing mailed this

____ day of ___________ 20__, to:

 

{Name of Opposing Counsel}

{Address}

{City}, {State} {Zip}

Attorney for Defendant

 

By ___________________________________