Greater New York Mutual Case Summary
PLAINTIFF’S REQUESTS FOR ADMISSION
Plaintiff, Greater New York Mutual, by and through undersigned counsel and pursuant to Rule 36 of the Superior Court Rules of Civil Procedure, request that, Defendant Joseph P. Spadaro & Sons, Inc., admit to the truth of the following facts and admit to the genuineness of the attached documents. In accordance with Rule 36, your responses must be filed within thirty (30) days after service of these requests your response to each request must specify an objection, admit or deny the matter, or set forth in detail the reason why you cannot truthfully admit or deny. Any matter(s) not addressed within thirty (30) days will be deemed admitted. INSTRUCTIONS
1. Each sub-part to a numbered request is intended …show more content…
Admit that installing the Pasco brand sheer rings you installed on a horizontal pipe hanging from the ceiling places creates the risk that the couplings will detach due to horizontal sheering.
10. Admit that a reasonably prudent plumber has a duty of care to install PVC piping in a manner that will withstand heavy rainstorms.
11. Admit that the damages the plaintiff’s insured’s premises were caused by the failure of couplings connecting two pieces of PVC pipe.
12. Admit that the couplings connecting two pieces of PVC pipe failed due to horizontal shearing.
13. Admit that section 705.19.4 of the District of Columbia Plumbing Code governs sanitary drainage systems.
14. Admit that the system you were contracted to work on was not a sanitary drainage system.
15. Admit that you were contracted to work on a storm drainage system.
16. Admit that in a storm drainage system, piping, plumbing, components, and materials used in the collection and conveyance systems shall be manufactured of materials approved for the intended application and compatible with any disinfection and treatment systems used.
17. Admit that the Pasco brand sheer rings bearing model number SR22 have not been approved for use to couple suspended storm water drainage piping.
Respectfully
Plaintiff, Greater New York Mutual, by and through undersigned counsel and pursuant to Rule 36 of the Superior Court Rules of Civil Procedure, request that, Defendant Joseph P. Spadaro & Sons, Inc., admit to the truth of the following facts and admit to the genuineness of the attached documents. In accordance with Rule 36, your responses must be filed within thirty (30) days after service of these requests your response to each request must specify an objection, admit or deny the matter, or set forth in detail the reason why you cannot truthfully admit or deny. Any matter(s) not addressed within thirty (30) days will be deemed admitted. INSTRUCTIONS
1. Each sub-part to a numbered request is intended …show more content…
Admit that installing the Pasco brand sheer rings you installed on a horizontal pipe hanging from the ceiling places creates the risk that the couplings will detach due to horizontal sheering.
10. Admit that a reasonably prudent plumber has a duty of care to install PVC piping in a manner that will withstand heavy rainstorms.
11. Admit that the damages the plaintiff’s insured’s premises were caused by the failure of couplings connecting two pieces of PVC pipe.
12. Admit that the couplings connecting two pieces of PVC pipe failed due to horizontal shearing.
13. Admit that section 705.19.4 of the District of Columbia Plumbing Code governs sanitary drainage systems.
14. Admit that the system you were contracted to work on was not a sanitary drainage system.
15. Admit that you were contracted to work on a storm drainage system.
16. Admit that in a storm drainage system, piping, plumbing, components, and materials used in the collection and conveyance systems shall be manufactured of materials approved for the intended application and compatible with any disinfection and treatment systems used.
17. Admit that the Pasco brand sheer rings bearing model number SR22 have not been approved for use to couple suspended storm water drainage piping.
Respectfully