Read without ads and support Scribd by becoming a Scribd Premium Reader.
See Premium Plans
 
IN THE CIRCUIT COURT OFMONTGOMERY COUNTY, ALABAMAIN RE THE MARRIAGE OF ) DOMESTIC RELATIONS DIVISION)LISA BOYD FULLER ))AND ) CASE NO.: DR-2012-900235)MARK EVERETT FULLER )Wife and Husband. )
PLAINTIFF’S
REQUEST FOR ADMISSIONS
Comes now the Plaintiff, and requests
the
Defendant to answer the following request foradmissions pursuant to Rule 36 of the Alabama Rules of Civil Procedure within thirty (30) days after theservice of this request.The Plaintiff submits this request for admissions by and through Floyd Minor, her attorney of record, requesting that it be answered pursuant to Alabama Rules of Civil Procedure.
Preliminary
 
Statement and Definitions:
The following preliminary statement and definitions apply to each of the requests for admissionsset forth hereunder and they are deemed to be incorporated therein.
A.
The terms “you” and your, as they are used herein, refer to the
Defendant, andinclude any and all agent(s), servant(s), and employee(s) of the Plaintiff including, but notlimited to,
Defendant’s
lawyer(s) and to any other person or persons acting pursuant to the
Defendant’s
direction.B. T
he singular number and the masculine gender, as used herein, shall be deemed toinclude the plural, the feminine, or the neuter. as may be appropriate.
C.
The term “person” as used herein, shall be deemed to include, in the plural as well as
singular, any natural person, firm, association, partnership, joint venture, corporation, or other legal entityunless the context is otherwise indicated.
 
ELECTRONICALLY FILED4/20/2012 1:38 PMDR-2012-900235.00CIRCUIT COURT OFMONTGOMERY COUNTY, ALABAMAFLORENCE CAUTHEN, CLERK
 
D.
The answers to the requests for admissions should be based on all information,including, but not limited to, information contained in writing, known or available to you, including, butnot limited to, all information in the possession of your attorney(s), accountant(s), employee(s), and/ortheir firm(s), corporation(s), and other person(s) acting on your behalf or under your control.E. If you cannot answer any request for admission fully after exercising due diligence tomake inquiries and secure the information requested, please so state and answer each request foradmission to the extent you deem possible, specifying the portion of the request you claim you are unableto answer fully and completely and specifying the facts upon which you rely to support your contentionthat you are unable to answer the request fully and completely and state what knowledge, information, orbelief you have concerning the unanswered portion of such request.F. This request for admission is continuing in nature so as to require you to filesupplemental answers and responses if you obtain further information before the trial of this case asrequired by the Alabama Rules of Civil Procedure.
REOUEST FOR ADMISSION TO THE PLAINTIFF
1. Admit or deny that you have had an extramarital affair with a person or persons duringthe course of your marriage to the Plaintiff.2. Admit or deny that you are continuing to have an extramarital affair.3. Admit or deny that you have stayed overnight and had sexual intercourse with a personor persons other than your spouse during the course of your marriage.4. Admit or deny that you have had sexual intercourse with a person or persons other thanyour spouse during the course of your marriage.5. Admit or deny that you have admitted to your spouse that you have had sexualintercourse with a person or persons other than your spouse during the course of your marriage.6. Admit or deny that the Defendant is a good parent to your minor child.7. Admit or deny that you have driven a vehicle while under the influence of alcohol during
 
the course of your marriage.8. Admit or deny that you have driven a vehicle while under the influence of alcohol, andwith one or more of your children in the vehicle as passengers, during the course of your marriage.9. Admit or deny that you have withheld any information in response to Plaintiff 
’s
interrogatories served contemporaneously herewith.10. Admit or deny that you have withheld any documents in response to Plaintiff 
’s r 
equestfor production of documents served contemporaneously herewith.11. Admit or deny that you have paid for the travel expenses of a person or persons otherthan your spouse that you were having sexual relations with during the course of your present marriage.12. Admit or deny that you have cursed your spouse or directed abusive language to yourspouse.13. Admit or deny that you have hit, kicked, struck, or otherwise physically abused yourspouse during the course of your marriage.14. Admit or deny that you have hit, kicked, struck, or otherwise physically abused yourchildren during the course of your marriage to the Plaintiff.15. Admit or deny that you have received psychological care or counseling during yourpresent marriage.16. Admit or deny that you are addicted to prescription medication.17. Admit or deny that you have withheld the name and address of any fact and/or expertwitness whom you may call at the time of the trial of this case.18. Admit or deny that you are aware that this request for admissions is to be answered byyou under oath, and may be used as material testimony at the time of the trial of this case.
s/ Floyd MinorFLOYD MINOR (MIN004)JOHN OLSZEWSKI (OLS004)
Search
Search History:
Searching...
Result 00 of 00
00 results for result for
  • p.
    • Notes
    Load more