REQUEST FOR ADMISSIONS OF FACTS

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

PERSONA

ADDRESS

Plaintiff

vs.

PIVOT OCCUPATIONAL HEALTH

ADDRESS

and

PIVOT PHYSICAL THERAPY

ADDRESS

and

OSBORNE SOCIAL VENTURES, LLC

ADDRESS

and

PERSONA

Individually and as an Agent of the

Co-Defendant Pivot Occupational Health

ADDRESS

and

OFFICER 

In his Individual Capacity

ADDRESS

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* CIVIL ACTION NO:

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and *
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OFFICER 
In his Individual Capacity *
ADDRESS
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Defendants. *
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PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS OF FACTS TO: DEFENDANT 

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

    1. Admit that Officer David Winch is liable for the claims asserted by Lawrence Mills.

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

    1. Admit that Officer David Winch committed and is liable for all of the claims alleged in Plaintiff’s Complaint.

    1. Admit that David Winch is an officer of the law.

    1. Admit that David Winch received a complaint lodged by Lawrence Mills addressed to the Internal Affairs Department.

    1. Admit that no action has been taken against Officer Timothy Hader.

Respectfully submitted,

PERSONA

Dated: July 1, 2021 

ADDREESS

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:

PERSONA

PERSONA

ADDRESS

 

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