Florida Request for Admissions: Rear-End Collision Cases

Plaintiff, pursuant to Rule 36, requests that the Defendant admit the truth to the following statements, within thirty (30) days of the date of service hereof, for use in this proceeding only and subject to all applicable objections that may be interposed at trial.

1. On (date) the vehicle Defendant was driving came into contact with the rear of the vehicle in which the Plaintiff was driving (or a passenger).

2. At the time of the collision, there were no obstructions to your vision.

3. At the time just prior to the collision, Defendant was traveling at a speed that did not allow him to bring the vehicle to a complete stop without striking the vehicle that the Plaintiff was driving (or in which the Plaintiff was a passenger) in the rear.

4. Defendant failed to see Plaintiff's car in sufficient time to take appropriate action to avoid hitting the vehicle in which Plaintiff was driving (or a passenger).

5. There was not sufficient distance between Defendant's vehicle and the Plaintiff's vehicle (or the vehicle in which the Plaintiff was a passenger) to allow Defendant sufficient time to avoid hitting it.

6. Defendant failed to apply the brakes prior to hitting the Plaintiff's vehicle (or the vehicle in which the Plaintiff was a passenger).

7. Defendant failed to apply the brakes with sufficient time to avoid hitting the Plaintiff's vehicle (or the vehicle in which the Plaintiff was a passenger).