Requests for Admission in an Florida Automobile Accident Case call 1800-HURT-911

Requests for Admission in an Florida Automobile Accident Case call 1800-HURT-911

NOW COMES the plaintiff, by and through counsel, who hereby requests, pursuant to Rule 36 of the Rules of Civil Procedure, that the defendant make the following admissions for the purpose of this action only and subject to all pertinent objections to the admissibility which may be interposed at trial. The response to this request shall be made within 30 days after service of this document or they are deemed admitted by the defendant.

1. That the plaintiff incurred medical bills between the dates of October 1, 2009 ¬and December 6, 2009 with the following medical facilities and/or physicians in the following amounts: (Insert the dates of the medical bills, the name of the facility, and the amount of the bill with the total to date).

2. That as a result of the injuries sustained in the automobile collision which is the subject of this action, the plaintiff incurred loss of income from his employment in the amount of (insert amount) as substantiated in a letter from John Brown, manager of the plaintiff's employer.

3. That as a result of the automobile collision which is the subject of this claim, the automobile operated by the plaintiff incurred property damages amounting to $7,000 as set forth in an estimate from ACME Body Shop and that such property dam¬age included the necessity to replace the rear bumper, trunk, and caused repair to the rear frame of the subject automobile.

4. That as a result of the automobile collision which is the subject of this claim, the automobile operated by the defendant incurred substantial property damage in¬cluding the necessity to replace the front bumper, headlights, grill, and left front wheel.

5. That the photographs, copies of which are attached hereto as Admission Re¬quests Exhibits 1, 2, 3, and 4 are fair and accurate representations of the damage done to the plaintiff's automobile resulting from the collision which is the subject of this matter.

6. That the defendant, just prior to the collision which is the subject of this claim, noticed that traffic had stopped in front of him and that he was unable to stop his ve¬hicle in time.

7. That the plaintiff had stopped his vehicle just prior to the collision at the inter¬section of Congress and State Streets because a red light was in operation at such inter¬section.

8. That the defendant applied his brakes prior to the collision and swerved to the right just prior to the collision between the vehicles operated by the plaintiff and the defendant.

9. That the medical bills incurred by the plaintiff subsequent to the date of the au¬tomobile collision which is the subject of this claim were fair, reasonable, and neces¬sary with proof as to causation and the responsibility therefore to be left for trial.

10. That the defendant had operated his vehicle in the area in which the collision occurred on occasions prior to the collision which is the subject of this claim.

11. That the defendant's speed just prior to the collision was between 15 miles per hour and 25 miles per hour as stated in defendant's interrogatory answers number 22 and 24.

12. That the emergency record from the State Medical Center of October 1, 2009- at 1:50 p.m. relating to the plaintiff indicates a diagnosis of "acute cervical strain" with the directions that the plaintiff "wear a cervical collar and seek the services of an orthopedic specialist."

13. That the plaintiff incurred injuries resulting from the collision between the ve¬hicles operated by the plaintiff and the defendant on October 1, 199 with the nature and extent of such injuries to be left for proof at trial.

14. That subsequent to the automobile collision which is the subject of this claim, the plaintiff was unable to perform certain physical activities at work and at leisure, the nature and extent of which shall be left for proof at trial.

15. That as a result of the injuries sustained by the plaintiff, the plaintiff pur¬chased and consumed certain prescription medicines including, but not necessarily limited to, Ibuprofen, Flexeril, and certain over the counter medicines including, but not limited to, Tylenol and aspirin.

16. That subsequent to the automobile collision which is the subject of this claim, the plaintiff was transported to the State Medical Center by the Johnson City Medical Crisis Unit and that the bill for such rescue service was $125.

17. That if the defendant had operated his vehicle at a greater distance between such vehicle and the plaintiff's vehicle he would have been able to stop behind the plaintiff's vehicle without locking his brakes, without swerving, and would have been able to avoid striking the plaintiff from the rear.

18. That on October 1, 2009 a vehicle operated by the defendant and a vehicle op¬erated by the plaintiff collided with significant force in Johnson City in the afternoon of that day.