Plaintiff's Req-Admns & Interrogs-Uninsured Driver

PLAINTIFF’S REQUEST TO ADMIT AND INTERROGATORIES

DIRECTED TO DEFENDANT

NOW COMES Plaintiff, , by and through counsel, the Law Office of , P.C., and pursuant to MCR 2.300 and MCR 2.312, and hereby demands the following requests to admit be answered under oath, within twenty-eight (28) days by the defendant, and that failure to admit or deny in accordance with [MCR 2.312], said requests to admit directed to defendant shall be deemed admitted.

Pursuant to MCR 2.309, plaintiff hereby requests that defendant answer, under oath, the following interrogatories to be served upon the undersigned attorney for plaintiff within twenty-eight (28) days.

REQUEST TO ADMIT #1: Admit that a motor vehicle collision occurred on **** on **** Road, near the intersection of ****, in **** County, Michigan, when defendant failed to yield the right of way and negligently drove a motor vehicle into the path of another motor vehicle which was driven by ****.

ANSWER:

INTERROGATORY #1: If your answer to request to admit #1 is anything other than an unqualified admission:

a. state in detail the facts upon which you base your answer and the reason for the answer;

b. list by name and address, each witness, including any expert witness who will testify as to the facts upon which you base your answer; and

c. identify and provide copies of all documents that support your answer.

ANSWER:

REQUEST TO ADMIT #2: Admit that at the time of the collision on ****, defendant was an uninsured motorist.

ANSWER:

INTERROGATORY #2: If your answer to request to admit #2 is anything other than an unqualified admission:

d. state in detail the facts upon which you base your answer and the reason for the answer;

e. list by name and address, each witness, including any expert witness who will testify as to the facts upon which you base your answer; and

f. identify and provide copies of all documents that support your answer.

ANSWER:

REQUEST TO ADMIT #3: Admit that at the time of the collision on ****, defendant was operating an uninsured motor vehicle.

ANSWER:

INTERROGATORY #3: If your answer to request to admit #3 is anything other than an unqualified admission:

g. state in detail the facts upon which you base your answer and the reason for the answer;

h...