`Benton County Circuit Court
`Brenda DeShields, Circuit Clerk
`2019-Oct-07 14:19:51
`04CV-19-2489
`C19WD05 : 3 Pages
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`IN THE CIRCUIT COURT OF BENTON COUNTY, ARKANSAS
`CIVIL DIVISION
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`KERMIT PLUMLEE and
`SUZANNE PLUMLEE
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`v.
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`JENNA WALKER
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`CASE NO. __________
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` PLAINTIFFS
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`DEFENDANT
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`PLAINTIFFS
` FIRST REQUEST FOR ADMISSIONS
`TO DEFENDANT, JENNA WALKER
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`Plaintiffs, Kermit Plumlee (hereinafter “Kermit”) and Suzanne Plumlee (hereinafter
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`“Suzanne”), propound the following Requests for Admissions to Defendant, Jenna Walker
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`(hereinafter “Defendant”) and requests that Defendant respond in writing, separately, under oath
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`within thirty (45) days of the date of service of a copy thereof pursuant to the Arkansas Rules of
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`Civil Procedure:
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`REQUEST FOR ADMISSION NO.1:
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`Admit that you were the driver of the 2009
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`Chevrolet Cobalt involved in the motor vehicle accident on March 17, 2018.
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`REQUEST FOR ADMISSION NO. 2:
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`Admit that you were the owner of the 2009
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`Chevrolet Cobalt involved in the motor vehicle accident on March 17, 2018.
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`REQUEST FOR ADMISSION NO. 3:
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`Admit that you were solely responsible for driving
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`the vehicle in a safe and proper manner.
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`REQUEST FOR ADMISSION NO. 4:
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`Admit that you were at fault for the collision on
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`March 17, 2018.
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`REQUEST FOR ADMISSION NO. 5:
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`Admit that you had insurance at the time of the
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`accident on March 17, 2018.
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`REQUEST FOR ADMISSION NO. 6:
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`Admit that you caused harm to Plaintiff Kermit as a
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`result of the accident on March 17, 2018.
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`REQUEST FOR ADMISSION NO. 7:
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`Admit that you caused harm to Plaintiff Susanne as
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`a result of the accident on March 17, 2018.
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`REQUEST FOR ADMISSION NO. 8:
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`Admit that Plaintiff Kermit did nothing to cause the
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`March 17, 2018 collision.
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`REQUEST FOR ADMISSION NO. 9:
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`Admit that Plaintiff Susanne did nothing to cause
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`the March 17, 2018 collision.
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`REQUEST FOR ADMISSION NO. 10: Admit that there is no other third party responsible
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`for the accident in question.
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`REQUEST FOR ADMISSION NO. 11: Admit that you were properly served in accordance
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`with the Arkansas Rules of Civil Procedure.
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`REQUEST FOR ADMISSION NO. 12: Admit that Plaintiff Kermit should be made whole for
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`his pain and suffering caused by the bodily injuries sustained in the accident of March 17, 2018,
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`which is the subject of the Complaint filed in this matter.
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`REQUEST FOR ADMISSION NO. 13: Admit that Plaintiff Susanne should be made whole for
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`her pain and suffering caused by the bodily injuries sustained in the accident of March 17, 2018,
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`which is the subject of the Complaint filed in this matter.
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`REQUEST FOR ADMISSION NO. 14: Admit that Plaintiff Kermit should be permitted to
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`receive reasonable medical treatment for the injuries suffered in the accident of March 17, 2018,
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`which is the subject of the Complaint filed in this matter.
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`REQUEST FOR ADMISSION NO. 15: Admit that Plaintiff Susanne should be permitted to
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`receive reasonable medical treatment for the injuries suffered in the accident of March 17, 2018,
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`which is the subject of the Complaint filed in this matter.
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`Respectfully submitted,
`PHIL VOTAW & ASSOCIATES
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`______________________________
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`Phil Votaw, ABA#: 2000163
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`Josh Jackson, ABA#: 2018058
`9 North 9th Street
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`Fort Smith, AR 72901
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`Phone: 479-434-6200
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`Fax: 479-649-9700
`phil@votawlaw.com
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`josh@votawlaw.com
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`Attorneys for Plaintiff
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