Plaintiff’s Request For Admissions To Defendant

COMES NOW, by counsel, and propounds the following Requests for Admissions to Defendant. Said Request for Admissions are hereby propounded pursuant to Rule 4:11 of the Supreme Court of Virginia. A response is required within twenty-one (21) days. All instructions set forth in that Rule are incorporated herein by reference in their entirety as if set forth verbatim. Plaintiff hereby requests Defendant to admit or deny the following:

Instructions
  1. The terms "you" and/or "Defendant" refer to Defendant (name the Defendant).
  2. The term "collision" refers to the 4/23/09 motor vehicle collision as described in the Complaint.
ADMISSIONS

1. On 4/23/09, Defendant was the driver of a vehicle involved in a three car motor vehicle collision with vehicles driven by (name and name).

Response:

2. At the time of the collision, Defendant was traveling westbound on Lorton Road in Fairfax County, Virginia.

Response:

3. Immediately prior to the collision, the vehicle driven by Plaintiff was at a complete stop on westbound Lorton Road in Fairfax County, Virginia.

Response:

4. Immediately prior to the collision, the vehicle driven by (third party behind Plaintiff's car) was at a complete stop on westbound Lorton Road in Fairfax County, Virginia.

Response:

5. At the time of the collision, Defendant rear-ended the vehicle driven by (third party).

Response:

6. Defendant caused the collision with (vehicle stopped behind Pl's vehicle).

Response:

7. No other person caused and/or contributed to the collision between Defendant and the vehicle driven by (third party stopped behind Plaintiff).

Response:

8. At the time of the collision, the force of the impact from Defendant's vehicle propelled (third part stopped behind plaintiff)'s vehicle into the rear of the vehicle driven by plaintiff.

Response:

9. Defendant caused the collision between the vehicle driven by (third party stopped behind plaintiff) and the vehicle driven by plaintiff.

Response:

10. No other person caused and/or contributed to the collision between the vehicle driven by third party and the vehicle driven by plaintiff.

Response:

11. The subject collision was caused by the sole negligence of Defendant.

Response:

12. You have no evidence that any act and/or omission of Plaintiff caused or contributed to the subject collision.

Response:

13. You have no evidence that any act and/or omission of the third party stopped behind the plaintiff caused or contributed to the subject collision.

Response:

14. Plaintiff was injured as a proximate result of the subject collision.

Response:

15. Defendant received a traffic citation for failure to pay full time and attention as a result of the collision.

Response:

16. Defendant had the opportunity to contest the traffic citation for failure to pay full time and attention, but voluntarily elected not to do so.

Response:

17. Defendant admitted guilt for the charge of failure to pay full time and attention arising out of the collision.

Response:

18. Defendant prepaid the traffic citation for failure to pay full time and attention on May 5, 2009 in lieu of appearing in court.

Response:

19. Defendant was aware that prepayment of the traffic citation would be deemed a waiver of court hearing and entry of guilty plea.

Response:

20. The traffic citation clearly stated that prepayment of the citation would be deemed a waiver of a court hearing and entry of guilty plea.

Response:

21. At the time of the collision, there were no unusual or emergency conditions on the road.

Response:

23a. The bill or invoice of Inova Health System for services rendered to Plaintiff on 4/23/09 for $370.00, a copy of which was previously produced, is an authentic, accurate statement of charges actually made by those who provided the treatment, service or product to Plaintiff.

Response:

23b. The bill or invoice of Inova Health System for services rendered to Plaintiff on 4/23/09 for $370.00, a copy of which was previously produced, is reasonable in amount, considering the prevailing cost of such treatment, service, or product in the community in which the services were rendered.

Response:

23c. The bill or invoice of Inova Health System for services rendered to Plaintiff on 4/23/09 for $370.00, a copy of which was previously produced, was medically necessary to treat Plaintiff for injuries sustained in the subject collision.

Response:

23d. The bill or invoice of Inova Health System for services rendered to Plaintiff on 4/23/09 for $370.00, a copy of which was previously produced, was prepared and kept in the ordinary course of Inova Health System's business.

Response:

24a. The bill or invoice of Best Practices, Inc. for services rendered to Plaintiff on 4/23/09 for $308.00, a copy of which was previously produced, is an authentic, accurate statement of charges actually made by those who provided the treatment, service or product to Plaintiff.

Response:

24b. The bill or invoice of Best Practices, Inc. for services rendered to Plaintiff on 4/23/09 for $308.00, a copy of which was previously produced, is reasonable in amount, considering the prevailing cost of such treatment, service, or product in the community in which the services were rendered.

Response:

24c. The bill or invoice of Best Practices, Inc. for services rendered to Plaintiff on 4/23/09 for $308.00, a copy of which was previously produced, was medically necessary to treat Plaintiff for injuries sustained in the subject collision.

Response:

24d. The bill or invoice of Best Practices, Inc. for services rendered to Plaintiff on 4/23/09 for $308.00, a copy of which was previously produced, was prepared and kept in the ordinary course of Best Practices, Inc.'s business.

Response:

25a. The bill or invoice of Eric G. Dawson, M.D. for services rendered to Plaintiff from 4/26/09 - 7/2/09 for $830.00, a copy of which was previously produced, is an authentic, accurate statement of charges actually made by those who provided the treatment, service or product to Plaintiff.

Response:

25b. The bill or invoice of Eric G. Dawson, M.D. for services rendered to Plaintiff from 4/26/09 - 7/2/09 for $830.00, a copy of which was previously produced, is reasonable in amount, considering the prevailing cost of such treatment, service, or product in the community in which the services were rendered.

Response:

25c. The bill or invoice of Eric G. Dawson, M.D. for services rendered to Plaintiff from 4/26/09 - 7/2/09 for $830.00, a copy of which was previously produced, was medically necessary to treat Plaintiff for injuries sustained in the subject collision.

Response:

25d. The bill or invoice of Eric G. Dawson, M.D. for services rendered to Plaintiff from 4/26/09 - 7/2/09 for $830.00, a copy of which was previously produced, was prepared and kept in the ordinary course of Eric G. Dawson, M.D., P.C.'s business.

Response:

26a. The bill or invoice of Alliance Rehab, LLC for services rendered to Plaintiff from 4/28/09 - 6/26/09 for $9,345.00, a copy of which was previously produced, is an authentic, accurate statement of charges actually made by those who provided the treatment, service or product to Plaintiff.

Response:

26b. The bill or invoice of Alliance Rehab, LLC for services rendered to Plaintiff from 4/28/09 - 6/26/09 for $9,345.00, a copy of which was previously produced, is reasonable in amount, considering the prevailing cost of such treatment, service, or product in the community in which the services were rendered.

Response:

26c. The bill or invoice of Alliance Rehab, LLC for services rendered to Plaintiff from 4/28/09 - 6/26/09 for $9,345.00, a copy of which was previously produced, was medically necessary to treat Plaintiff for injuries sustained in the subject collision.

Response:

26d. The bill or invoice of Alliance Rehab, LLC for services rendered to Plaintiff from 4/28/09 - 6/26/09 for $9,345.00, a copy of which was previously produced, was prepared and kept in the ordinary course of Alliance Rehab, LLC's business.

Response:

27a. The bill or invoice of Hossein Okuiyan, M.D. for services rendered to Plaintiff on 4/5/09 for $110.00, a copy of which was previously produced, is an authentic, accurate statement of charges actually made by those who provided the treatment, service or product to Plaintiff.

Response:

27b. The bill or invoice of Hossein Okuiyan, M.D. for services rendered to Plaintiff on 4/5/09 for $110.00, a copy of which was previously produced, is reasonable in amount, considering the prevailing cost of such treatment, service, or product in the community in which the services were rendered.

Response:

27c. The bill or invoice of Hossein Okuiyan, M.D. for services rendered to Plaintiff on 4/5/09 for $110.00, a copy of which was previously produced, was medically necessary to treat Plaintiff for injuries sustained in the subject collision.

Response:

24d. The bill or invoice of Hossein Okuiyan, M.D. for services rendered to Plaintiff on 4/5/09 for $110.00, a copy of which was previously produced, was prepared and kept in the ordinary course of Hossein Okuiyan, M.D., P.C.'s business.

Respectfully Submitted,

By: _________________________________

Law Offices of Jeremy Flachs

Jeremy Flachs, Esq.

Jeremy.Flachs@Flachslaw.com

Counsel for Plaintiff

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