SELARZ LAW CORP.

1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 PLAINTIFF S REQUEST FOR ADMISSIONS, SET ONE SELARZ LAW CORP. 11777 San Vicente Blvd., Suite 702 Los Angeles, California 90049 Tel: Fax: SELARZ LAW CORP. DANIEL E. SELARZ (State Bar No. 287555) 11777 San Vicente Blvd., Suite 702 Los Angeles, California 90049 Telephone: Facsimile: Attorneys for Plaintiff, [CLIENT S NAME(S)] SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF [COUNTY ], [DISTRICT] [PLAINTIFF(S)], an individual, Plaintiff, vs.

2 [DEFENDANT(S)], and DOES 1 to [#], inclusive, Defendants. Case No. [ ] Honorable [ ] [Dept. [#]] PLAINTIFF S REQUEST FOR ADMISSIONS, SET ONE Action Filed: [ ] Trial Date: [ ] PROPOUNDING PARTY : PLAINTIFF [CLIENT S NAME] RESPONDING PARTY : DEFENDANT [DEFENDANT S NAME] SET NUMBER : ONE Plaintiff [CLIENT S NAME] ( PLAINTIFF ) requests that Defendant [DEFENDANT S NAME] ( DEFENDANT ) answer fully the following set of Request for Admissions, in writing and under oath, pursuant to California Code of Civil Procedure Section , and that said answers be signed, verified, and served within thirty (30) days after service is made upon you.

3 Please be cautioned that if you deny any matters upon which admissions are sought and plaintiff is able to prove the truth thereof, California Code of Civil Procedure Section permits plaintiff to apply to the Court for an order that defendant pay to Plaintiff the reasonable expenses incurred in making such proof. /// 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFF S REQUEST FOR ADMISSIONS, SET ONE SELARZ LAW CORP. 11777 San Vicente Blvd., Suite 702 Los Angeles, California 90049 Tel: Fax: DEFINITIONS A.

4 DEFENDANT, YOU and YOUR shall mean Defendant [DEFENDANT S NAME]. B. PLAINTIFF shall mean PLAINTIFF [CLIENT S NAME]. C. SUBJECT INCIDENT means and refers to the incident on [DATE OF INCIDENT] described in PLAINTIFF s Complaint upon which this suit is founded. REQUESTS FOR ADMISSION REQUEST FOR ADMISSION NO. 1: Admit that YOU were negligent at the time of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 2: Admit that YOUR negligence was the proximate cause of the SUBJECT INCIDENT.

5 REQUEST FOR ADMISSION NO. 3: Admit that PLAINTIFF was not negligent in causing the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 4: Admit that there is no evidence that PLAINTIFF committed any negligent acts that contributed to causing the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 5: Admit that there is no evidence that PLAINTIFF committed any negligent omissions that contributed to causing the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 6: Admit that YOU were not looking in the direction YOU were traveling at the time of the SUBJECT INCIDENT.

6 REQUEST FOR ADMISSION NO. 7: Admit that immediately prior to impact, the vehicle operated by PLAINTIFF was lawfully in PLAINITFF s lane at the time of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 8: Admit that the front of the vehicle YOU were operating struck the vehicle the PLAINTIFF was operating on the date of the SUBJECT INCIDENT. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 PLAINTIFF S REQUEST FOR ADMISSIONS, SET ONE SELARZ LAW CORP. 11777 San Vicente Blvd.

7 , Suite 702 Los Angeles, California 90049 Tel: Fax: REQUEST FOR ADMISSION NO. 9: Admit that PLAINTIFF did not contribute to the cause of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 10: Admit that the vehicle that YOU were driving struck the PLAINTIFF s vehicle on the date of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 11: Admit that had YOU been driving at a slower speed, YOU would have avoided striking the PLAINTIFF s vehicle on the date of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO.

8 12: Admit that YOUR actions were the sole cause of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 13: Admit that no other entity contributed to cause the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 14: Admit that significant injury can occur in a motor vehicle accident. REQUEST FOR ADMISSION NO. 15: Admit that PLAINTIFF was injured as a result of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 16: Admit that PLAINTIFF was caused to suffer various injuries as a result of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO.

9 17: Admit that PLAINTIFF was injured as a result of the SUBJECT INCIDENT caused by YOU. REQUEST FOR ADMISSION NO. 18: Admit that YOU have no evidence to support the affirmative defense that the PLAINTIFF assumed the risk of PLAINTIFF S injuries. REQUEST FOR ADMISSION NO. 19: Admit that YOU have no evidence to support the affirmative defense that the PLAINTIFF was contributorily negligent. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 PLAINTIFF S REQUEST FOR ADMISSIONS, SET ONE SELARZ LAW CORP.

10 11777 San Vicente Blvd., Suite 702 Los Angeles, California 90049 Tel: Fax: REQUEST FOR ADMISSION NO. 20: Admit that The PLAINTIFF did sustain injuries as a result of the accident which took place on the date of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 21: Admit that The PLAINTIFF did require necessary medical treatment as a result of the SUBJECT INCIDENT. REQUEST FOR ADMISSION NO. 22: Admit that the medical treatment rendered was medically necessary as a result of the SUBJECT INCIDENT complained of in the PLAINTIFF s Complaint.