DEMAND FOR A VERIFIED BILL OF PARTICULARS
PLEASE TAKE FURTHER NOTICE that the undersigned demands that the answering defendant serves upon plaintiff within thirty (30) days, a verified Bill of Particulars of the claims alleged in said defendant’s Answer, setting forth specifically and in detail the answers to the following inquiries:
1. As to the First Defense, particularize and identify the collateral sources rendered and the amount of collateral offset that is claimed.
2. As to the Second Defense, set forth the factual basis that Plaintiff’s causes of action are barred by the applicable statute of limitations.
3. As to the Third Defense, set forth the factual basis that the requesting Defendant was not negligent in any way in Plaintiff’s …show more content…
As to the Fourth Defense, set forth the factual basis that the requesting Defendant was not a substantial factor in Plaintiff’s injuries, damages and loss as alleged in the Verified Complaint.
5. As to the Fifth Defense, set forth the factual basis that Plaintiff failed to mitigate damages.
6. As to the Sixth Defense, particularize how and in what manner the plaintiff knew or were otherwise aware of the negligence of those responsible for the incidents alleged in the Verified Complaint constituted a separate, independent, superseding, intervening culpable act or acts which constitute the sole proximate cause of the accident or occurrence alleged.
7. As to the First Affirmative Defense:
a) particularize how and in what manner the plaintiff fails to state a cause of action, in whole or in part, in which relief can be granted against the defendant.
b) particularize and identify the specific defenses that are alleged as the basis for the First Affirmative Defense, and the factual basis for asserting them against the plaintiff in this case.
8. As to the Second Affirmative Defense, particularize and identify the specific culpable conduct and/or contributory negligence on the part of the plaintiff, or by someone over whom the answering defendant had to control;
9. As to the Third Affirmative
PLEASE TAKE FURTHER NOTICE that the undersigned demands that the answering defendant serves upon plaintiff within thirty (30) days, a verified Bill of Particulars of the claims alleged in said defendant’s Answer, setting forth specifically and in detail the answers to the following inquiries:
1. As to the First Defense, particularize and identify the collateral sources rendered and the amount of collateral offset that is claimed.
2. As to the Second Defense, set forth the factual basis that Plaintiff’s causes of action are barred by the applicable statute of limitations.
3. As to the Third Defense, set forth the factual basis that the requesting Defendant was not negligent in any way in Plaintiff’s …show more content…
As to the Fourth Defense, set forth the factual basis that the requesting Defendant was not a substantial factor in Plaintiff’s injuries, damages and loss as alleged in the Verified Complaint.
5. As to the Fifth Defense, set forth the factual basis that Plaintiff failed to mitigate damages.
6. As to the Sixth Defense, particularize how and in what manner the plaintiff knew or were otherwise aware of the negligence of those responsible for the incidents alleged in the Verified Complaint constituted a separate, independent, superseding, intervening culpable act or acts which constitute the sole proximate cause of the accident or occurrence alleged.
7. As to the First Affirmative Defense:
a) particularize how and in what manner the plaintiff fails to state a cause of action, in whole or in part, in which relief can be granted against the defendant.
b) particularize and identify the specific defenses that are alleged as the basis for the First Affirmative Defense, and the factual basis for asserting them against the plaintiff in this case.
8. As to the Second Affirmative Defense, particularize and identify the specific culpable conduct and/or contributory negligence on the part of the plaintiff, or by someone over whom the answering defendant had to control;
9. As to the Third Affirmative