Plaintiff's Request for Admissions & Interrogatories-Rear-End Collision

PLAINTIFF’S REQUEST FOR ADMISSIONS

AND INTERROGATORIES DIRECTED

TO DEFENDANT

NOW COMES Plaintiff, Daniel Czaja, by and through his attorneys, the Law Offices of Michael J. Morse, P.C., by Michael J. Morse, and pursuant to MCR 2.312, 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: Please admit that on September 14, 1999, your vehicle hit the rear end of the car that Plaintiff was occupying.

RESPONSE #1:

REQUEST #2: Please admit that at the time of the collision, there were no obstructions to your vision.

RESPONSE #2:

REQUEST #3: Please admit that you were traveling at a speed that would not allow you to bring your vehicle to a stop without hitting the Plaintiff’s car.

RESPONSE #3:

REQUEST #4: Please admit that you did not apply your brakes in enough time to avoid hitting the Plaintiff’s car.

RESPONSE #4:

REQUEST #5: Please admit that there were no sudden emergencies which caused you to rear-end the Plaintiff’s vehicle.

RESPONSE #5:

REQUEST 6#: Please admit that Plaintiff did nothing to contribute to or cause this motor vehicle accident.

RESPONSE #6:

REQUEST #7: Please admit that you are 100% at fault in causing the accident of September 14, 1999.

RESPONSE #7:

REQUEST #8: Please admit that you do not have any defenses to causing this accident.

RESPONSE #8:

REQUEST #9: Please admit that the Plaintiff suffered a jaw injury which was caused by the September 14, 1999 accident.

RESPONSE # 9:

REQUEST #10: Please admit that the Plaintiff suffered injuries to his knees caused by the September 14, 1999 accident.

RESPONSE #10:

REQUEST #11: Please admit that the injuries suffered by the Plaintiff to his jaw and knees from the September 14, 1999 accident have prevented him from returning to the life he...