Plaintiff's Request For Admissions & Interrogatories

PLAINTIFF’S REQUEST FOR ADMISSIONS

DIRECTED TO DEFENDANT

NOW COMES Plaintiff, by and through his attorneys, and pursuant to [MCR 2.312], and hereby demands that the Defendant file a responsive pleading within twenty-eight (28) days hereof to the Request for Admissions which are set forth below. Pursuant to the provisions of [MCR 2.312], a failure to respond to these Requests for Admissions within the time prescribed will be deemed an admission of the Request.

REQUEST #1: As to the nature of plaintiff’s injuries, please admit each of the following facts claimed by plaintiff in this case:

A. Plaintiff sustained a bimalleolar fracture of the left ankle joint consisting of comminuted displaced fractures of the medial and lateral malleolus bones.

B. In non-medical terms, plaintiff’s injury consisted of multiple breaks and fragmentation of the bones that make up the outside and inside of the ankle joint.

C. Plaintiff’s injuries required open reduction internal fixation surgery which means that 12 metal screws and plates were surgically implanted in plaintiff’s ankle under general anesthesia during an operation that took two hours to complete.

D. The metal hardware implanted in plaintiff’s leg will remain in place indefinitely.

E. The bimalleolar fracture of plaintiff’s ankle also damaged the supporting ligaments, muscles and tendons in the vicinity of the ankle joint.

F. Plaintiff’s injuries were of such a nature that plaintiff suffered intense pain requiring the use of narcotic pain medications, including Vicodin, which plaintiff was required to take three times a day for a period of six weeks.

G. Plaintiff’s injuries were of such a nature that plaintiff was unable to sleep normally for period of two months during which time plaintiff was extremely fatigued for lack of rest.

H. The nature of plaintiff’s injuries required that his leg be encased in a fiberglass cast which remained on plaintiff’s leg for eight weeks.

1. Plaintiff’s injuries were of such a nature that after the cast was removed, plaintiff was required to wear an orthotic brace on his ankle for a period of six months.

J. Plaintiff’s injuries were of such a nature that plaintiff was unable to work at all for a period of one month and thereafter returned to work but was only able to work for approximately 25 hours per week and only able to do limited activities, all of which continued for approximately three months.

RESPONSE #1:

REQUEST #2: As to the extent of plaintiff’s...