REQUEST FOR ADMISSIONS OF FACTS

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

Plaintiff Name
Plaintiff Address
Plaintiff

vs.

Defendant Company A
Defendant Address A

and

Defendant Company B
Defendant Address B

and

Defendant Company C
Defendant Address C

and

Defendant Name A
Individually and as an Agent of the
Co-Defendant Company A
Defendant Address A

and

Officer Name A
In his Individual Capacity
Defendant Address D

CIVIL ACTION NO:

and

Officer Name B
In her Individual Capacity
Defendant Address E

Defendants.

PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS OF FACTS TO: DEFENDANT

Plaintiff, by himself and on his own behalf, hereby requests that Defendant Name A 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 between Plaintiff Name and Defendant Name A, where Defendant Name A received a complaint lodged by Plaintiff Name against Officer Name C for misconduct (the “occurrence” or “incident”). The incident occurs when Defendant Name A receives a complaint from Plaintiff Name.

Admit that Officer Name A is liable for the claims asserted by Plaintiff Name.

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

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

Admit that Defendant Name A is an officer of the law.

Admit that Defendant Name A received a complaint lodged by Plaintiff Name addressed to the Internal Affairs Department.

Admit that no action has been taken against Officer Name C.

Respectfully submitted,

Plaintiff Name

Dated: July 1, 2021

Plaintiff 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:

Defendant Name A
Defendant Address A

 

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