RONALD GOODSON
2212 Via Lorna,
Camarillo, CA. 93012
Phone Number (805) 754 5371
Email Address tonysnypizzeria31@gmail.com
In Pro Per
SUPERIOR COURT OF CALIFORNIA
IN AND FOR THE COUNTY OF VENTURA
| ALEXANDER TRON, an individual Plaintiff, vs. RONALD GOODSON, individually and d/b/a TONY’S NY PIZZERIA, TONY’S PIZZA BRO’S, a California LLC, DOES 1 through 10, inclusive, Defendants. | ))))))))))))))))))) | Case No.: 56-2021-00552590-CU-WT-VTA DEFENDANT’S REQUEST FOR ADMISSIONS SET ONE |
PROPOUNDING PARTY: Plaintiff ALEXANDER TRON
RESPONDING PARTY: Defendant RONALD GOODSON
SET NUMBER: ONE
DEFENDANT RONALD GOODSON (“DEFENDANT”) requests that Plaintiff Alexander Tron (“PLAINTIFF”) answer fully the following set of Request for Admissions, in writing and under oath, pursuant to California Code of Civil Procedure Section 2033.010, and that said answers be signed, verified, and served within thirty (30) days after service is made upon you. 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 2033.010 permits plaintiff to apply to the Court for an order that defendant pay to Plaintiff the reasonable expenses incurred in making such proof.
DEFINITIONS
- “PLAINTIFF,” “YOU” and “YOUR” shall mean PLAINTIFF Alexander Tron.
- “DEFENDANT” shall mean DEFENDANT Ronald Goodson.
- “SUBJECT INCIDENT” means and refers to the incident described in PLAINTIFF’s Complaint upon which this suit is founded.
REQUEST FOR ADMISSIONS
REQUEST FOR ADMISSION NO. 1:
Admit that YOU deliberately contravened employee policy at the time of the SUBJECT INCIDENT.
REQUEST FOR ADMISSION NO. 2:
Admit that YOUR deliberate contravention of employee policy was the proximate cause of the SUBJECT INCIDENT.
REQUEST FOR ADMISSION NO. 3:
Admit that DEFENDANT was not negligent in causing the SUBJECT INCIDENT.
REQUEST FOR ADMISSION NO. 4
Admit that there is no evidence that DEFENDANT committed any negligent acts that contributed to causing the SUBJECT INCIDENT.
REQUEST FOR ADMISSION NO. 5:
Admit that there is no evidence that DEFENDANT committed any negligent omissions that contributed to causing the SUBJECT INCIDENT.
REQUEST FOR ADMISSION NO. 6:
Admit that YOU willingly manipulated the time clock entries during YOUR employment with the DEFENDANT.
REQUEST FOR ADMISSION NO. 7:
Admit that YOU were aware that manipulation of the time clock entries is forbidden.
REQUEST FOR ADMISSION NO. 8:
Admit that PLAINTIFF did not contribute to the cause of the SUBJECT INCIDENT.
REQUEST FOR ADMISSION NO. 9:
Admit that YOUR actions were the sole cause of the SUBJECT INCIDENT.
REQUEST FOR ADMISSION NO. 10:
Admit that no other entity contributed to cause the SUBJECT INCIDENT.
Dated: _________________
BY: ____________________
RONALD GOODSON
Defendant
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