Plaintiff who was involved in a West Palm Beach Car accident requesto for admissions to Defendant

PLAINTIFF WHO WAS INVOLVED IN A WEST PALM BEACH CAR ACCIDENT
v. C.A. No.
DEFENDANT

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

Plaintiff who was involved in a West Palm Beach Car accident requests that the Defendant admit the authenticity of the attached documents:
(1) Insurance policy no. PL4759
(2) Correspondence from [insurance adjuster] to the Plaintiff who was involved in a West Palm Beach Car accident dated [insert date]
(3) Reservation of rights letter dated [insert date] authored by [name of author] to Plaintiff who was involved in a West Palm Beach Car accident
(4) Denial of coverage letter from [name of insurance adjuster] to Plaintiff who was involved in a West Palm Beach Car accident dated [insert date]
(5) E-mail communication from [name of insurance adjuster] to Plaintiff who was involved in a West Palm Beach Car accident dated [insert date]

Note: Consider the following follow-up interrogatory with respect to any request for admissions:

If your response to any request for admissions is other than an unqualified admission, then for each such request for admission provide the following information:
(a) State all facts that you contend support, in any manner, your refusal to admit or any qualifications on your admission;
(b) Identify all documents and other tangible things that support, in any manner, your refusal to admit or any qualification of your admissions;
(c) State the name and address of the custodian of all documents and tangible things identified in response to the preceding interrogatory;
(d) State the names and addresses of all persons, including agents and consultants, purporting to have any knowledge of factual data on which you base your refusal to admit or any qualifications to your admission.