Prepare a response to these questions. When your cussed the matter with Ms. Bennett, she told you that she did in fact have min problems and that her husband had filed for divorce last week.
PART III DISCO You have been asked to prepare a response to these questions. When your cussed the matter with Ms. Bennett, she told you that she did in fact have min problems and that her husband had filed for divorce last week. She admitted to. ing a marriage counselor prior to her employment with defendant. However does not believe that any of this is relevant to the case. She assures you that all her medical problems were caused by the defendant’s actions. She does acknow edge that her bills have been paid by insurance. She also tells you that when was terminated she replied, "You can’t fire me. I quit." Prepare a draft of appropri answers to requests for admission. Be sure to assert proper objections. THE DOUGLASS FINANCIAL SERVICES, INC. CASE Assignment for Chapter 13: Request to Request for Admissions Your attorney tells you that Douglass Financial, Inc., your client, was recently served with Requests for Admissions. Using a proper format for your state court, deny of object to each of the following requests for admissions sent by plaintiff to your die ent, Douglass Financial, Inc.: A. Admit that each of the following statements is true: 1. Defendant Evan Portman was in the course and scope of his employment with Douglass Financial, Inc. when he consumed alcohol at an office party on December 19. 2. When Evan Portman left the office party sponsored by Douglass Financial Inc., he was in such an inebriated state that it was not safe for him to drive an automobile. 3. All employees of Douglass Financial, Inc. were required to attend the com pany’s office party held on December 19. 4. The automobile accident that is the subject of this lawsuit was caused by the negligence of defendant Evan Portman. 5. Plaintiff, Jessica Hewitt, was not negligent in any matter contributing to the automobile accident that is the subject of this lawsuit. ENDNOTES 1. Henry Kelston, "Are We on the Cusp of Major Changes to E-Discovery Rules?" Law Technology News (April 17, 2013), http://www.law.com/jsp/law technologynews/PubArticlel IN Are We_on the_Cusp of
APPENDIX B: BENNETT AND DOUGLASS RESEARCH FILES INTRODUCTION Jessica Hewitt v. Douglass Financial Services, Inc., Creative Catering and Evan Portman This action results from an automobile accident involving Jessica Hewitt and Evan Portman, as a result of which Ms. Hewitt suffered serious injuries. The accident occurred in an intersection controlled by traffic lights. The accident occurred when the front of the vehicle driven by Hewitt (a Ford) hit the passenger side of a vehicle driven by Portman (a Honda). Independent witnesses indicate that Hewitt entered the intersection just as the traffic light turned green and that Portman entered the intersection on a yellow or red light. Witnesses also indicate that both parties were traveling fast. Police were called to the scene of the accident and when they spoke to Port- man noted that he appeared to be intoxicated. A subsequent blood test confirmed that he was over the legal limit. Portman told police that he had just left work, and that there had been a social gathering for employees during which alcohol was provided by his employer. Ms. Hewitt has hired an attorney to pursue a claim for her damages against Mr. Portman, his employer Douglass Financial Services, and Creative Catering. You work for the law firm that represents Douglass Financial Services, Inc.
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