N 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: KRISTEN CRISPIN

Plaintiff, by himself and on his own behalf, hereby requests that Defendant Kristen Crispin 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 Lawrence Mills and Kristen Crispin, where Kristen Crispin proceeded to extract a blood sample from Lawrence Mills pursuant to a warrant authorizing the same, which warrant was procured by Officer Timothy Hader (the “occurrence” or “incident”). The incident occurs when Kristen Crispin touches Lawrence Mills in order to extract a blood sample.

1. Admit that Kristen Crispin was on duty on the date 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 Kristen Crispin is an employee of Pivot Occupational Healthcare.
6. Admit that Lawrence Mills did not appear intoxicated at the time of the incident.
7. Admit that you attempted to withdraw a blood sample from Lawrence Mills.
8. Admit that you touched Lawrence Mills to withdraw blood.
9. Admit that Lawrence Mills had not expressly, or implied, given his consent to be touched.
10. Admit that Lawrence Mills had not expressly, or implied, given his consent to withdraw a blood sample.
11. Admit that you touched Lawrence Mills pursuant to the warrant obtained by Officer Timothy Hader.

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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