Request for Admission Model Products Liability Case 1

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COMES NOW the plaintiff and pursuant to the rules of civil procedure files herewith the following Request for Admissions which will stand admitted unless within 30 days hereafter the defendant specifically denies the request for admissions:

1. Admit that federal regulation—and State regulation—require a warning as to the use of the product in the language of the respective statute to be affixed to each and every product.

2. Admit that the product manufactured and distributed by defendant did not contain the aforesaid warning at the time the product was marketed.

3. Admit that the defendant had knowledge of the violation of both the federal and state statute before the marketing of the product.

4. Admit that defendant had in fact failed to warn the plaintiff and the consuming public of the serious risk of harm from the use or possession of the product.

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