Florida Automobile Collision Requests for Admissions

Florida Automobile Collision Requests for Admissions

PLAINTIFF[‘S/S’] REQUESTS FOR ADMISSION

Plaintiff[s] served upon Defendant these requests for admission, answers which should be made fully in writing within thirty (30) days after service and returned to the undersigned counsel of record. Failure to answer these requests deems them admitted without further Court order. The answers should specifically admit or deny the matter or set forth in detail the reasons that Defendant cannot truthfully admit or deny the matter.

You are advised that if you fail to admit the truth of any matter as requested in these requests, plaintiff[s] will apply to the Court for an order requiring you to pay plaintiff[s] the reasonable expenses incurred in proving the truth of the matter, including reasonable attorneys’ fees.

REQUESTS FOR ADMISSION

1. Admit or deny that Defendant’s negligence proximately caused the collision made the basis of this lawsuit.

RESPONSE:

2. Admit or deny that Defendant’s negligence was the sole proximate cause of the collision made the basis of this lawsuit.

RESPONSE:

3. Admit or deny that Defendant’s negligence was a proximate cause of the collision made the basis of this lawsuit.

RESPONSE:

4. Admit or deny that Defendant owned the vehicle involved in the collision with Plaintiff’s[s’] vehicle on [DATE] while traveling on [STREET].

RESPONSE:

5. Admit or deny that at the time of the incident in question, Defendant was operating the vehicle with the consent of its owner.

RESPONSE:

6. Admit or deny that the vehicle being operated by Defendant collided with Plaintiff’s[s’] vehicle on [DATE] while traveling on [STREET].

RESPONSE:

7. Admit or deny that Defendant failed to pay proper attention to traffic conditions immediately prior to the collision made the basis of this lawsuit.

RESPONSE:

8. Admit or deny that Defendant failed to pay proper attention to traffic conditions at the time of the collision made the basis of this lawsuit.

RESPONSE:

9. Admit or deny that Defendant failed to yield the right-of-way to Plaintiff at the time of the collision made the basis of this lawsuit.

RESPONSE:

10. Admit or deny that Defendant [DESCRIBE NEGLIGENT ACT OR OMISSION] immediately prior to the collision made the basis of this lawsuit.

RESPONSE:

11. Admit or deny that Defendant [DESCRIBE NEGLIGENT ACT OR OMISSION] at the time of the collision made the basis of this lawsuit.

RESPONSE:

12. Admit or deny that Defendant was cited by the investigating officer for [TRAFFIC OFFENSE].

RESPONSE:

13. Admit or deny that Defendant pleaded guilty to the charge of [TRAFFFIC OFFENSE].

RESPONSE:

14. Admit or deny that Defendant plead no contest to the charge of [TRAFFIC OFFENSE].

RESPONSE:

15. Admit or deny that Defendant was found guilty of the charge of [TRAFFIC OFFENSE].

RESPONSE:

16. Admit or deny that as of [DATE OF REQUEST FOR ADMISSIONS], Plaintiff[s] [has/have] incurred reasonable and necessary medical expenses in the amount of at least [$ AMOUNT] as a result of the injuries [he/she/they] suffered in the collision made the basis of this lawsuit.

RESPONSE:

17. Admit or deny that as of [DATE OF REQUEST FOR ADMISSIONS], Plaintiff[s] [has/have] incurred medical expenses in the amount of at least [$ AMOUNT], as a result of the injuries [he/she/they] suffered in the collision made the basis of this lawsuit.

RESPONSE:

18. Admit or deny that the [$ AMOUNT] in medical expenses incurred by Plaintiff[s] are in keeping with the usual and customary charges for medical treatment, services, therapy, devices, equipment and medication of the kind received by Plaintiff[s], at the time and in the locality where [he/she/they] received them.

RESPONSE:

19. Admit or deny that the [$ AMOUNT] in medical expenses incurred by Plaintiff[s] were in reasonable probability made necessary by the collision made the basis of this lawsuit.

RESPONSE:

20. Admit or deny that as of [DATE OF REQUEST FOR ADMISSIONS], Plaintiff[s] [has/have] incurred reasonable and necessary medical expenses in the amount of [$ AMOUNT] for treatment provided by [NAME OF PROVIDER], as a result of the injuries she suffered in the collision made the basis of this lawsuit.

RESPONSE:

21. Admit or deny that as of [DATE OF REQUEST FOR ADMISSIONS], Plaintiff[s] [has/have] incurred medical expenses in the amount of [$ AMOUNT] for treatment provided by [NAME OF PROVIDER], as a result of the injuries [he/she/they] suffered in the collision made the basis of this lawsuit.

RESPONSE:

22. Admit or deny that the charges referred to in the preceding request are in keeping with the usual and customary charges for medical treatment, services, therapy, devices, equipment and medication of the kind received by Plaintiff[s], at the time and in the locality where [he/she/they] received them.

RESPONSE:

23. Admit or deny that the charges referred to in the preceding request were for medical expenses and care made necessary by the collision made the basis of this lawsuit.

RESPONSE:

24. Admit or deny that as of [DATE OF REQUEST FOR ADMISSIONS], Plaintiff[s] [has/have] incurred reasonable and necessary medical expenses in the amount of [$ AMOUNT] for prescription medication provided by [NAME OF PHARMACY OR OTHER MEDICATION PROVIDER] as a result of the injuries [he/she/they] suffered in the collision made the basis of this lawsuit.

RESPONSE:

25. Admit or deny that as of [DATE OF REQUESTS FOR ADMISSIONS], Plaintiff[s] [has/have] incurred medical expenses in the amount of [$ AMOUNT] for prescription medication provided by [NAME OF PHARMACY OR OTHER MEDICATION PROVIDER] as a result of the injuries [he/she/they] suffered in the collision made the basis of this lawsuit.

RESPONSE:

26. Admit or deny that the charges referred to in the preceding request are in keeping with the usual and customary charges for medical treatment, services, therapy, devices, equipment and medication of the kind received by Plaintiff[s], at the time and in the locality where [he/she/they] received them.

RESPONSE:

27. Admit or deny that the charges referred to in the preceding request were for medical expenses and care made necessary by the collision made the basis of this lawsuit.

RESPONSE:

28. Admit or deny that Plaintiff’s[s’] vehicle sustained at least [$ AMOUNT] in damage as a result of the collision made the basis of this lawsuit.

RESPONSE:

29. Admit or deny that [$ AMOUNT] represents a fair and reasonable cost for the repair of the damage to Plaintiff’s[s’] vehicle as a result of the collision made the basis of this lawsuit.

RESPONSE:

30. Admit or deny that [$ AMOUNT] represents the difference in fair market value of Plaintiff’s[s’] vehicle immediately before and immediately after the collision made the basis of this lawsuit.

RESPONSE:

31. Admit or deny that Defendant and/or his/her insurer paid [$ AMOUNT] to Plaintiff[s] for repair of their vehicle.

RESPONSE:

32. Admit or deny that Plaintiff’s[s’] vehicle was towed from the scene.

RESPONSE:

33. Admit or deny that Plaintiff[s] incurred rental vehicle charges as a result of the collision made the basis of this lawsuit.

RESPONSE:

34. Admit or deny that Plaintiff[s] incurred at least [$ AMOUNT] in rental vehicle charges as a result of the collision made the basis of this lawsuit.

RESPONSE:

35. Admit or deny that [$ AMOUNT] represents the fair and reasonable cost for the rental of a temporary replacement vehicle while Plaintiff’s[s’] vehicle was being repaired as a result of the collision made the basis of this lawsuit.

RESPONSE:

36. Admit or deny that Defendant [and/or his/her insurer] paid [$ AMOUNT] to Plaintiff[s] for the rental of a temporary replacement vehicle while Plaintiff’s[s’] vehicle was being repaired as a result of the collision made the basis of this lawsuit.

RESPONSE:

37. Admit or deny that Plaintiff[s] incurred towing and storage charges as a result of the collision made the basis of this lawsuit.

RESPONSE:

38. Admit or deny that Plaintiff[s] incurred at least [$ AMOUNT] in towing and storage charges as a result of the collision made the basis of this lawsuit.

RESPONSE:

39. Admit or deny that [$ AMOUNT] represents the fair and reasonable cost for the towing and temporary storage of Plaintiff’s[s’] vehicle as a result of the collision made the basis of this lawsuit.

RESPONSE:

40. Admit or deny that Defendant [and/or his/her insurer] paid [$ AMOUNT] to Plaintiff[s] for the towing and temporary storage of Plaintiff’s[s’] vehicle as a result of the collision made the basis of this lawsuit.

RESPONSE: