PLAINTIFFS FIRST REQUEST FOR ADMISSIONS OF FACTS

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE NEW CASTLE COUNTY

PERSONA     

ADDRESS

Plaintiff

vs.

PIVOT OCCUPATIONAL HEALTH

ADDRESS

and

PIVOT PHYSICAL THERAPY

ADDRESS

and

OSBORNE SOCIAL VENTURES, LLC

ADDRESS

and

KRISTEN CRISPIN

Individually and as an Agent of the

Co-Defendant Pivot Occupational Health

ADDRESS

and

OFFICER DAVID WINCH

In his Individual Capacity

ADDRESS

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* CIVIL ACTION NO:

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OFFICER 
In his Individual Capacity *
ADDRESS
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Defendants. *
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PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS OF FACTS TO: DEFENDANT – TIMOTHY HADER

Plaintiff, by himself and on his own behalf, hereby requests that Defendant Officer David Winch respond to the following requests for admission under the provisions of Del. R. Civ. P. Super. Ct. 36. Within thirty days of service of this request, said Defendants are to make the following admissions for the purpose of this action only subject to all pertinent objections to admissibility which may be interposed at the trial.

Stipulated below all requests for admission shall pertain to the events of the night of the incident (the “occurrence” or “incident”). The occurrence begins with Officer Timothy Hader, in the company of Officer David Winch, causing the Plaintiff to pull over on allegations of speeding, improper change of lane, and impeding traffic.

    1. Admit that Officer Hader was on duty on the night of the incident.

    1. Admit that Officer Hader is liable for the claims asserted by Lawrence Mills.

    1. Admit that all the facts alleged in Plaintiff’s complaint are true.

    1. Admit that Officer Hader committed and is liable for all of the claims alleged in Plaintiff’s Complaint.

    1. Admit that on the night of the incident, Lawrence Mills was caused to pull over by Officer Hader.

    1. Admit that Lawrence Mills was not showing signs of intoxication.

    1. Admit that Officer Hader attempted to administer a horizontal gaze nystagmus test.

    1. Admit that Officer Hader did not attempt to administer a breathalyzer test prior to Lawrence Mills’ arrest.

    1. Admit that Officer Hader did not attempt to administer any other test prior to Lawrence Mills’ arrest.

    1. Admit that Lawrence Mills cooperated while Officer Hader placed him under arrest.

    1. Admit that Lawrence Mills cooperated while Officer Hader conducted a body search.

    1. Admit that Lawrence Mills cooperated while Officer Hader conducted a body search.

Respectfully submitted,

PERSONA     

Dated: July 1, 2021 

ADDRESS

Plaintiff

 

 

 

 

 

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY on this 1st day of July, 2021 that a copy of Plaintiff’s Motion for Authorization to File Electronically was served via email to the Defendants at:

 

ADDRESS

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