Requests for Admission 1 - with Subsequent Conviction in Car Accident Case
To Defendant and Your Attorney(s) of Record:
In accordance with the provisions of § of the Code of Civil Procedure, you are requested to affirmatively admit or deny the following Requests For Admissions, and/or state in detail why each such request, in whole or in part, cannot be admitted or denied, in writing and under oath.
At all times herein mentioned, "Plaintiff" means _________ and "Defendant" means___________
Attorney for Plaintiff:
1. Admit that on the [number] day of [month] 20, you were the owner of that certain 20, [make/model] automobile.
2. Admit that on the [number] day of [month] 20, you and you alone were operating such vehicle at or near Street with its intersection at Street, in the City of , County of _____ .
3. Admit that at approximately —.m., that certain vehicle operated by you collided with the rear end of the vehicle operated by the plaintiff.
4. Admit that there were no defects, mechanical or otherwise, existing on your vehicle at the time of the collision with the vehicle operated by the plaintiff.
5. Admit that there were no obstructions or impairment of your vision preventing you from seeing, in all or part of the vehicle operated by the plaintiff immediately prior to the collision.
6. Admit that you were cited by officers of the [city] Police Department for traveling at a speed of in excess of 40 m.p.h.
7. Admit that at the location of the collision between your vehicle and the plaintiff's that the speed limit was 15 m.p.h.
8. Admit that at the time of the collision plaintiff had lawfully stopped for a red traffic light.
9. Admit that the plaintiff did not contribute to the collision in any negligent manner.
10. Admit that the plaintiff did not assume the risks of the subject collision.
11. Admit that no other party or parties contributed to the subject collision.
12. Admit that the plaintiff's injuries were not contributed to, in whole or in part, by any alleged prior condition or ailment.
13. Admit that the plaintiff was in fact injured in person and body as a result of the subject collision.
14. Admit that at all times you were driving with a suspended driving license.
15. Admit that you were further cited by officers of the [city] Police Department for driving under the influence of alcohol.
16. Admit that you were convicted of a felony as a result of your driving while under the influence of alcohol.