Example Slip and Fall Requests for Admission

Below are sample requests for admission for a slip and fall lawsuit.

Requests for Admission are particularly useful in slip-and-fall cases because they streamline the litigation process by clarifying which facts are in dispute and which are agreed upon by all parties. These requests can be crucial for establishing key elements of the case such as the property owner’s knowledge of the hazardous condition, the reasonableness of their actions to prevent accidents, or the maintenance of the premises.  You do not want to spend time deposing someone when the answer could be clarified with a simple admissions request.

For instance, you might use Requests for Admission to confirm that the defendant owned the property at the time of the accident, acknowledge the existence of surveillance footage, or admit that no warning signs were posted near a known hazard. By securing admissions on these points, you can focus your efforts on disputed issues that truly affect the outcome of the case, such as the extent of the plaintiff’s injuries or the calculation of damages. This not only helps in building a stronger case but also potentially reduces the time and cost – even for the defendant, actually –  associated with pretrial discovery and the trial by minimizing the number of issues that need litigating.

Example Slip-and-Fall Requests for Admission

IN THE CIRCUIT COURT FOR TALBOT COUNTY, MARYLAND RAYMOND MCKINNON
Plaintiff,
v. Case No.: _
________________
THE BEDFORD COUNTRY INN, LLC
Defendant

PLAINTIFF’S REQUESTS FOR ADMISSION TO DEFENDANTTO: The Bedford Country Inn, LLC, Defendant

FROM: Raymond McKinnon, Plaintiff

The Plaintiff, Raymond McKinnon, by and through his attorneys, Miller & Zois, LLC, requests that Defendant, The Bedford Country Inn, LLC, admit or deny the following statements of fact. If an objection is made, please state the reason for the objection.

REQUESTS FOR ADMISSIONS

1. Raymond McKinnon is a resident of Montgomery County, Maryland.
2. The Bedford Country Inn, LLC manages the premises known as The Bedford Country Inn, LLC, located in or near Talbot County, Maryland.
3. On or about May 17, 2023, Plaintiff was walking from a cottage toward the main building on premises owned, controlled, managed and maintained by The Bedford Country Inn, LLC, as identified in the Complaint.
4. The plaintiff had no alternative means to get from the cottage to the main building.
5. The plaintiff tripped and fell due to an unsecured wooden railroad tie that The Oaks placed and allowed to remain along a walkway intended for pedestrian use.
6. Raymond McKinnon did not in any way contribute to the fall alleged in the Complaint.
7. Raymond McKinnon did not in any way assume the risk of the collision or his injuries.
8. Raymond McKinnon was injured as a result of his fall.
9. Raymond McKinnon had the right to walk from the cottage to the main building at the time of the occurrence.
10. The Bedford Country Inn, LLC failed to keep post warnings about the condition of the walkway for pedestrian use.
11. The Bedford Country Inn, LLC failed to maintain a well-lit pathway.
12. The sole case of the accident complained of in the Complaint is due to the negligence of The Bedford Country Inn, LLC.
13. Admit that The Bedford Country Inn, LLC, did not ask or any of its agents or employees, to remove the wooden railroad tie on May 17, 2023.
14. Admit that at the time of the incident The Bedford Country Inn, LLC, were aware and knew that the wooden railroad tie was on the premises.
15. Admit that the wooden railroad tie referenced in the Complaint was dangerous.
16. Admit that you no longer have the wooden railroad tie.
17. Admit that you knew had notice that the railroad tie would be evidence at trial in this lawsuit.
18. Bellavista Properties, LLC owns the real property on which Plaintiff fell during the incident which is the subject of this lawsuit.
19. Bellavista Properties, LLC owns the real property located at 25876 Royal Oak Road, Easton, Maryland 21601.
20. On or about May 17, 2023, Plaintiff was walking from a cottage toward the main building on the property that was maintained by The Bedford Country Inn, LLC, as identified in the Complaint.
21. On or about May 17, 2023, Plaintiff was walking from a cottage toward the main building on the property that was managed by The Bedford Country Inn, LLC, as identified in the Complaint.
22. Plaintiff had no alternative means to get from the cottage to the main building on the evening of May 17, 2023, other than by using the path that he traveled.
23. The wooden railroad tie pictured below presents a tripping hazard to pedestrians:
24. The wooden railroad tie pictured below is lifted up off of the ground on the left end:
25. Raymond McKinnon did not contribute to his slip and fall injury, which is alleged in the Complaint.
26. Raymond McKinnon did not assume the risk of the injuries he suffered on May 17, 2023.
27. Raymond McKinnon was injured as a result of his fall on May 17, 2023.
28. Raymond McKinnon had the right to walk from the cottage to the main building on the evening of May 17, 2023.
29. Because of his fall on May 17, 2023, Raymond McKinnon had to get physical therapy.
30. The Bedford Country Inn, LLC did not place warning signs on outside areas of the subject premises, letting pedestrians know of things, if any, that they could trip over.
31. Plaintiff fell, at least in part, due to a wooden railroad tie that was located along a walkway on the subject property. (See Request for Admission No. 23, above, to understand what a railroad tie is.)
32. The Bedford Country Inn, LLC provided inadequate artificial lighting on the outside of the subject property.
33. The Bedford Country Inn, LLC, was at least partially responsible for the Plaintiff’s fall on May 17, 2023.
34. When Raymond McKinnon fell on May 17, 2023, he suffered pain.
35. The Bedford Country Inn, LLC, did not ask for any of its agents, contractors, or employees to remove any wooden railroad ties from the subject property in the year preceding the incident, which is the subject of this lawsuit. (See Request for Admission No. 23, above, to understand what a railroad tie is.)
36. At or around 10:00 p.m. on May 17, 2023, Plaintiff tripped and fell on an outside area of the property located at 276 Westley Road, Easton, Maryland 21601.
37. The Bedford Country Inn, LLC is liable for any of the injuries complained of in the Complaint.
38. At the time of the incident, Bedford Country Inn, LLC knew that the subject property had a wooden railroad tie on it. (See Request for Admission No. 23 to understand what a railroad tie is.)
39. At the time of the incident, Bedford Country Inn, LLC did not know that the subject property had any wooden railroad ties on it. (See Request for Admission No. 23 to understand what a railroad tie is.)
40. The Bedford Country Inn, LLC did not do anything that it thinks was wrong or improper on May 17, 2023.
41. Bedford Country Inn, LLC did not do anything that contributed to Raymond McKinnon’s injuries which he suffered on May 17, 2023.
42. Raymond McKinnon broke his leg when he fell on May 17, 2023.
43. Admit that there were no regular inspections conducted to ensure the walkway where the plaintiff fell was free from hazards on May 17, 2023.
44. Admit that The Bedford Country Inn, LLC did not have a policy in place for the regular maintenance and inspection of pedestrian pathways as of May 17, 2023.
45. Admit that The Bedford Country Inn, LLC did not report the incident involving Raymond McKinnon to any insurance company within 24 hours of its occurrence.
46. Admit that there have been previous incidents of guests tripping over obstacles on pathways within the premises of The Bedford Country Inn, LLC, prior to May 17, 2023.
47. Admit that The Bedford Country Inn, LLC did not provide Raymond McKinnon with any information or warning about potential hazards on the walkway prior to his accident on May 17, 2023.
48. Admit that the area where Raymond McKinnon fell lacked sufficient lighting to safely navigate the walkway on the evening of May 17, 2023.
49. Admit that The Bedford Country Inn, LLC has received prior complaints regarding the safety of the walkway where Raymond McKinnon fell.
50. Admit that after the incident on May 17, 2023, The Bedford Country Inn, LLC took measures to repair or improve the walkway where Raymond McKinnon fell.
51. Admit that The Bedford Country Inn, LLC does not have a comprehensive safety plan that addresses hazards on walkways and pedestrian areas.
52. Admit that employees or agents of The Bedford Country Inn, LLC were aware of the loose wooden railroad tie but failed to secure it prior to May 17, 2023.

Thoughts on These Requests for Admission

Requests for admission, when strategically employed, can dramatically streamline the discovery process and tighten the focus of litigation, especially in slip-and-fall cases. Their utility extends far beyond expediting case resolution. They can serve as a powerful tool in anchoring the facts early on in the litigation process and really pinning down the defendant’s case, sometimes before they have really had a chance to consider what their defense is or should be.

By compelling the opposing party to affirm or deny specific assertions related to the case, requests for admission can significantly narrow the issues for trial. This not only clarifies the points of contention but also minimizes unnecessary disputes over well-established facts.  You can end a lot of debate by pulling out a request for admission.  For example, in slip-and-fall cases, confirming the conditions of the premises or the defendant’s awareness of potential hazards through requests for admission can decisively influence the direction and scope of subsequent inquiries and testimony.

Furthermore, the tactical use of requests for admission can expose inconsistencies in the defense’s claims, enhancing the plaintiff’s credibility while potentially undermining the defendant’s reliability. Defendants will contradict what they admit or deny in requests for admission and you can use this. This is particularly impactful when the defendant provides denials that defy logical or observable facts, as these responses can later be highlighted in front of a jury to question the defense’s overall integrity and trustworthiness.

Incorporating requests for admission effectively requires careful drafting to ensure that each request is precise and directly relevant to the pivotal aspects of the case. This not only ensures compliance with court standards but also maximizes the likelihood of obtaining useful and actionable admissions. Additionally, these requests can effectively limit the scope of interrogatories and depositions, focusing those discovery tools on areas that truly require exploration, thereby conserving valuable legal resources and time.

Hopefully, our sample requests for admission are helpful to you in preparing your discovery. Good luck!

More Litigation Support

• Example slip and trip interrogatories
• Example slip and fall complaint
• Sample requests for production of documents
• More requests for admission