Date: October 8th, 2024 4:05 PM
Author: chandler (retired)
PLAINTIFF'S FIRST SET OF REQUESTS FOR ADMISSION TO DEFENDANT MICHAEL DOODIKOFF
INSTRUCTIONS: Pursuant to the applicable rules of civil procedure, you are requested to admit or deny the following statements within the time period specified by the rules. Each request should be admitted or denied in full or, if the request cannot be admitted or denied in full, please specify the part that is admitted and the part that is denied.
DEFINITIONS:
"You" or "Your" refers to Michael Doodikoff and any agents, representatives, or persons acting on his behalf.
"Document" or "Documents" has the broadest possible meaning ascribed under applicable rules of civil procedure, and includes but is not limited to writings, recordings, emails, text messages, and any electronic or physical representations of information.
REQUESTS FOR ADMISSION:
Request for Admission No. 1:
Admit that you are 50 years old or older.
Request for Admission No. 2:
Admit that you were born on or before January 1, 1974.
Request for Admission No. 3:
Admit that you were born on or before January 1, 1970.
Request for Admission No. 4:
Admit that you attended high school during the 1980s.
Request for Admission No. 5:
Admit that you attended college during the 1980s.
Request for Admission No. 6:
Admit that you were alive during the presidency of Richard Nixon.
Request for Admission No. 7:
Admit that you were alive during the United States Bicentennial celebration in 1976.
Request for Admission No. 8:
Admit that you were alive when Ronald Reagan was elected as President of the United States.
Request for Admission No. 9:
Admit that you were alive when the Berlin Wall fell in 1989.
Request for Admission No. 10:
Admit that you were alive when the 1992 United States presidential election occurred.
Request for Admission No. 11:
Admit that you have stated, either in writing or verbally, that you are over 50 years old.
Request for Admission No. 12:
Admit that you have represented yourself to others as being born in or before 1973.
Request for Admission No. 13:
Admit that you have stated your birth year as being 1973 or earlier.
Request for Admission No. 14:
Admit that you have not denied being over 50 years old when asked directly.
Request for Admission No. 15:
Admit that you have stated that you have grandchildren or are old enough to be a grandparent.
(http://www.autoadmit.com/thread.php?thread_id=5608561&forum_id=2],#48177771)