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

  1. “PLAINTIFF,”   “YOU” and   “YOUR” shall   mean   PLAINTIFF Alexander Tron.
  2. “DEFENDANT” shall mean DEFENDANT Ronald Goodson.
  3. “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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