`Washington County Circuit Court
`Kyle Sylvester, Circuit Clerk
`2019-Oct-16 14:01:48
`72CV-19-2290
`C04D01 : 4 Pages
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`IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS
`CIVIL DIVISION
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`JESSICA RILEY
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`VS.
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`ERICK TANGNESS,
`MICHELE TANGNESS, and
`PEYTON TANGNESS, a minor
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`NO. 72CV-19-2290
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`PLAINTIFF
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` DEFENDANTS
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`DEFENDANT ERICK TANGNESS’ RESPONSE TO PLAINTIFF’S
`FIRST REQUESTS FOR ADMISSIONS
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`Defendant Erick Tangness for his Response to Plaintiff’s First Requests
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`for Admissions, states:
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`REQUEST FOR ADMISSION NO. 1: Admit that you were the owner of
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`the 2013 Jeep Wrangler involved in the motor vehicle accident on April 12,
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`2017.
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`RESPONSE:
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`Admit.
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`REQUEST FOR ADMISSION NO. 2: Admit that you were solely
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`responsible for driving the vehicle in a safe and proper manner.
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`RESPONSE:
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`Deny; Defendant was not operating the 2013 Jeep
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`Wrangler during the incident described in the Complaint.
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`REQUEST FOR ADMISSION NO. 3: Admit that you had insurance at the
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`time of the accident on April 12, 2017.
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`RESPONSE:
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`Admit.
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`REQUEST FOR ADMISSION NO. 4: Admit that you caused harm to
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`Plaintiff as a result of the accident on April 12, 2017.
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`RESPONSE:
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`Deny; Defendant was not operating the 2013 Jeep
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`Wrangler during the incident described in the Complaint.
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`REQUEST FOR ADMISSION NO. 5: Admit that Plaintiff did nothing to
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`cause the April 12, 2017 collision.
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`RESPONSE:
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`Deny; Defendant does not possess
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`sufficient
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`information to eliminate fault on behalf of Plaintiff.
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`REQUEST FOR ADMISSION NO. 6: Admit that you were properly
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`served in accordance with the Arkansas Rules of Civil Procedure.
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`RESPONSE:
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`Deny; Defendant does not possess
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`sufficient
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`information to ascertain whether service of process was in accordance with the
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`Arkansas Rules of Civil Procedure.
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`REQUEST FOR ADMISSION NO. 7: Admit that the Plaintiff should be
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`made whole for her pain and suffering caused by the bodily injuries sustained
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`in the accident of April 12, 2017, which is the subject of the Complaint filed in
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`this matter.
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` RESPONSE:
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`Deny; Defendant does not possess
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`sufficient
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`information to determine if the injuries alleged in the Complaint are related to
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`the accident in question.
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`REQUEST FOR ADMISSION NO. 8: Admit that you gave permission to
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`Separate Defendant, Erick Tangness, to drive the 2013 Jeep Wrangler at the
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`2
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`time of the incident on April 12, 2017, which is the subject of the Complaint
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`filed in this matter.
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`RESPONSE:
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`Deny. Erick Tangness was not driving the Jeep at the
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`time of the accident described in the Complaint; Peyton Tangness was driving.
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`REQUEST FOR ADMISSION NO. 9: Admit that the Plaintiff should be
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`permitted to receive reasonable medical treatment for the injuries suffered in
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`the accident of April 12, 2017, which is the subject of the Complaint filed in
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`this matter.
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`RESPONSE:
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`Deny; Defendant is not a medical expert and cannot
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`speak to the reasonableness of Plaintiff’s medical treatment.
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`Respectfully submitted,
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`MUNSON, ROWLETT, MOORE
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`AND BOONE, P.A.
`REGIONS CENTER
`400 W. CAPITOL, SUITE 1900
`LITTLE ROCK, AR 72201
`501/374-6535
`john.moore@mrmblaw.com
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`BY: /s/ John E. Moore
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`JOHN E. MOORE
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`82111
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`3
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`CERTIFICATE OF SERVICE
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`I, John E. Moore, certify that a copy of the foregoing pleading was sent
`this 16th day of October, 2019, via the Clerk of the Washington County Circuit
`Court using the online filing system to the following counsel of record:
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`Phil Votaw
`Josh Jackson
`Phil Votaw & Associates
`9 North 9th St.
`Fort Smith, AR 72901
`phil@votawlaw.com
`josh@votawlaw.com
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`/s/ John E. Moore
`JOHN E. MOORE
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`4
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