Defendant to Plaintiff Request for Admissions

PLAINTIFF
v. C.A. No. ________________
DEFENDANT

DEFENDANT’S FIRST SET OF REQUESTS FOR ADMISSIONS TO PLAINTIFF WHO WAS INVOLVED IN A WEST PALM BEACH CAR ACCIDENT

In accordance with Federal Rule of Civil Procedure 36, Defendant requests that Plaintiff who was involved in a West Palm Beach Car accident admit the truth of the following within thirty (30) days:
1. Plaintiff who was involved in a West Palm Beach Car accident had actual notice of the claim asserted against Plaintiff who was involved in a West Palm Beach Car accident by [insert name of party] on July 1, 2001.
2. Plaintiff who was involved in a West Palm Beach Car accident did not provide any notice of the claim to the Defendant until Plaintiff who was involved in a West Palm Beach Car accident sent a letter dated November 4, 2002 to the Defendant.
3. Plaintiff who was involved in a West Palm Beach Car accident engaged in settlement discussions with [name of party] between July 1, 2001 and November 4, 2002.
4. Plaintiff who was involved in a West Palm Beach Car accident settled the claim with [insert party] by agreeing to pay the party $50,000.
5. Plaintiff who was involved in a West Palm Beach Car accident settled the claim with [name of party] before giving any notice of the claim to Defendant.
Defendant also requests that the Plaintiff who was involved in a West Palm Beach Car accident admit the genuineness of the following documents:
(a) Insurance policy issued to Plaintiff who was involved in a West Palm Beach Car accident with the effective date of [insert date], policy no. A147969.
(b) Letter dated November 4, 2002 from Plaintiff who was involved in a West Palm Beach Car accident ’s counsel to Defendant.
(c) Denial of coverage letter written by Defendant to Plaintiff who was involved in a West Palm Beach Car accident ’s counsel dated January 17, 2003.

DEFENDANT
By its attorneys,

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