UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION
| CHELSA S. BROWNPlaintiff, V. THE RENY COMPANYDefendant. | PLAINTIFF’S RESPONSE TO DEFENDANT’S FIRST REQUEST FOR ADMISSION |
COMES NOW Plaintiff, Chelsa S. Brown (“Responding Party”) and hereby responds to Defendant, the Remy Company (“Propounding Party”) Request for Admissions, Set One, as follows:
PRELIMINARY STATEMENT
The following responses are made solely for the purpose of this action. Each answer is subject to all appropriate objections which would require the exclusion of any statement contained herein, if the Request for Admission were propounded, or if the answer were made by, a witness present and testifying in court. All such objections and grounds are reserved and may be interposed at the time of trial.
The following responses are given without prejudice to the right to produce at trial any and all subsequently-discovered evidence relating to the proof of presently known material facts, if any, and to produce all evidence, whenever discovered, relating to the proof of subsequently discovered material facts. Responding party responds to these Requests for Admission based upon the information and belief presently known and available to the Responding Party and reserves the right to supplement or modify these responses based upon subsequently discovered or acquired information and/or documents.
Except for explicit facts submitted herein, no admissions of any nature whatsoever are implied nor should they be inferred. The fact that Responding Party has responded to any Request for Admission should not be taken as an admission or acceptance of the existence of any fact or facts set forth or assumed by any interrogatory, or that such answer constitutes admissible evidence. This Preliminary Statement is, by this reference, incorporated into each and every one of the following Responses to these Requests for Admission.
RESPONSE TO REQUEST FOR ADMISSIONS
RESPONSE TO REQUEST FOR ADMISSION NO. 1
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 2
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 3
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 4
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 5
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 6
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 7
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 8
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 9
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 10
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 11
Admitted. Plaintiff’s employment contract was terminated when the Plaintiff tested positive for COVID-19 and the same information was relayed to the Defendant.
RESPONSE TO REQUEST FOR ADMISSION NO. 12
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 13
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 14
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 15
Denied. The items in question were returned on December 26th, 2020.
RESPONSE TO REQUEST FOR ADMISSION NO. 16
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 17
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 18
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 19
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 20
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 21
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 22
Denied.
DATED: [insert date]
Respectfully submitted,
________________________________
Chelsa Brown
6201 Chapel Hill Blv., #116
Plano, TX 75093.
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