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

LAWRENCE MILLS

705 Winhall Way

Silver Spring, MD 20904

Plaintiff

vs.

PIVOT OCCUPATIONAL HEALTH

914 Justison St, Wilmington,

Delaware, 19801

and

PIVOT PHYSICAL THERAPY

1214 Beaver Brook Plaza Ste. A,

New Castle, DE 19720

and

OSBORNE SOCIAL VENTURES, LLC

251 Little Falls Drive

Wilmington, DE, 19807

and

KRISTEN CRISPIN

Individually and as an Agent of the

Co-Defendant Pivot Occupational Health

26 Colesbery Dr

Wilmington Manor, DE 19720

and

OFFICER DAVID WINCH

In his Individual Capacity

2162 New Castle Ave,

New Castle, DE 19720

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* CIVIL ACTION NO:

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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.
2. Admit that Officer Hader is liable for the claims asserted by Lawrence Mills.
3. Admit that all the facts alleged in Plaintiff’s complaint are true.
4. Admit that Officer Hader committed and is liable for all of the claims alleged in Plaintiff’s Complaint.
5. Admit that on the night of the incident, Lawrence Mills was caused to pull over by Officer Hader.
6. Admit that Lawrence Mills was not showing signs of intoxication.
7. Admit that Officer Hader attempted to administer a horizontal gaze nystagmus test.
8. Admit that Officer Hader did not attempt to administer a breathalyzer test prior to Lawrence Mills’ arrest.
9. Admit that Officer Hader did not attempt to administer any other test prior to Lawrence Mills’ arrest.
10. Admit that Lawrence Mills cooperated while Officer Hader placed him under arrest.
11. Admit that Lawrence Mills cooperated while Officer Hader conducted a body search.
12. Admit that Lawrence Mills cooperated while Officer Hader conducted a body search.

Respectfully submitted,

/s/ Justin Mills

Dated: July 1, 2021 Lawrence J. Mills

705 Winhall Way

Silver Spring, MD 20904

Telephone: (240) 338-4999

Plaintiff

CERTIFICATE OF SERVICE

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

Gordon, Fournaris & Marshall Dennehey Warner

Mammarella, P.A.  Coleman & Goggin

William M. Kelleher, Esq. (#003645) Aaron E. Moore (#6739)

Phillip A. Giordano, Esq. (#005756) 1007 N. Orange Street, Suite 600

1925 Lovering Avenue P.O. Box 8888 

Wilmington, DE 19806 Wilmington, DE 19899

wkelleher@gfmlaw.com  aemoore@mdwcg.com

pgiordano@gfmlaw.com

Kristen Crispin

933 Gray Street

New Castle, DE 19720

kristencrispin14@gmail.com

/s/ Justin Mills

          Lawrence J. Mills

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