Request For Admissions

 

JERALDINE S. SANTIAGO, PLAINTIFF VS. RAYMOND B. SANTIAGO, DEFENDANT REQUEST FOR ADMISSION OF FACTS AND GENUINENESS OF DOCUMENTS TO:

Raymond Santiago  C/o Atty. Glenford Catabian Valley 5, Sta. Ana Area, BF Homes, Paranaque City

FROM:

Jeraldine Santiago

C/o Atty. Butch Bulala 18 A2 Blk 17, Lot 5, Pilot Area, Brgy. Hernandez, Pasig City INSTRUCTIONS

A.  Pursuant to Rule 2-424, you are requested to file a full and complete written response to each of the following admissions. If you do not respond within 30 days after this request has been served upon you, each matter of which an admission is requested shall be deemed admitted. You or your attorney must sign your your response to the following admissions and serve your response upon counsel for the Defendant at the above address. B.  As to each matter of which an admission is requested, the response shall specify an objection, or shall admit or deny the matter, or shall set forth in detail the reason why the respondent cannot truthfully admit or deny it. The reasons for any objection shall be stated. stated. C.  A denial shall fairly meet the substance of the requested admission, and when good faith required that a party qualify an answer or deny only a part of the matter of which an

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admission is requested, the party shall specify so much of it as is true and deny or qualify the remainder. D.  A respondent may not give lack of information or knowledge as a reason for failure to admit or deny unless the respondent states that after reasonable inquiry the information known or readily obtainable by the respondent is insufficient to enable the respondent to admit or deny. E.  A party who considers that a matter of which is an admission is requested presents a genuine issue for trial may not, on that ground alone, object to the request but the party may, subject to the provisions of Maryland Rule 2-424(e), deny the matter or set forth reasons for not  being able to to admit admit or deny it. F.  Any matter admitted under this Rule is conclusively established unless the Court on motion  permits  permi ts withdra withdrawal wal or or amendment amendment.. REQUESTS FOR ADMISSION [requests from a child abuse case]

1.  The document attached as Exhibit A is a Safety Plan dated March 24, 2011, from the Worcester County Department of Social Services.

 

2. You and your sister, [sister’s name], were investigated by the Worcester County Department of Social Services for being verbally and physically abusive to your son, [child’s name]. name]. 3.  The child alleged that you pushed his head down to the ground and that you refer to you son by cussing at him. 4.  The child alleged that [sister’s name] locked name] locked him in a closet, shot him with a bee-bee gun, and threatened him with a knife.   Request for Admission of Facts & Genuineness of Documents Page 2 of 5

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5.  The Safety Plan issued by the Worcester County Department on March 24, 2011, states that, “[child’s name] should name] should not visit with his father, [father’s name], name], and his aunt, [sister’s name],, until further notice from Worcester County Department of Social Services.”  name] Services.”   6.  The Safety Plan lists no specific date for re-evaluation re- evaluation and states only “to be determined.”  determined.”  [requests from a property dispute case]

7.  The deed attached as Exhibit A is the deed by which [name] acquired [property]. 8.  The “fence . . . which extends over the property line between [next door property] and [property]” existed at the time [name] acquired [property].  [property].   [requests from a visitation case in which a military parent absconded with the child]  

9.  Defendant received orders to deploy to Iraq on September 5, 2007. 10. Defendant did not deploy to Iraq with the rest of Defendant’s company. 11. Defendant was listed Absent Without Without Leave (“AWOL”) from August 21, 2007 until September 12, 2007. 12. That Defendant received non-judicial punishment for being AWOL on November 8, 2007. 13. Defendant was again listed as AWOL on November 27, 2007. 14. Defendant has not been in contact with his commanding officer since November 27, 2007. 2 007.

 

15. Plaintiff has been denied visitation with the minor child [name] since December 10, 2007 until the date of this Request. 16. Defendant called Plaintiff on or around February 3, 2008. 17. During the February 3, 2008 phone phon e call, Defendant again denied visitation to the Plaintiff. 18. Defendant was not summoned to Fort Drum on June 19, 2008, the date of the scheduling conference in this case. 19. Defendant did not appear of his own volition at Fort Drum on June 19, 2008.   Request for Admission of Facts & Genuineness of Documents Page 3 of 5

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[requests from a custody case]

20. That you do not own the property located at [party’s home].  home].  21. That the only people who live at [ party’s home] are you, [friend] and [friend] and [child]. 22. That you have not had a job since prior to August 1, 2011. 23. That you are not related to Defendant. 24. That prior to June 2011, [child] never lived with you. 25. That you have never seen Defendant hit [child]. 26. That you have no photos of bruises on [child] that you believe were caused by Defendant. 27. That Defendant never agreed that you could become [child’s] [child’s] representative  representative payee for his social security benefits. 28. That you never notified Defendant you were placing [child] in therapy. 29. That you smoke marijuana. 30. That you have smoked marijuana since June 2011. 31. That you have smoked marijuana in front of [child]. 32. That you have never taken [child] to the dentist. [requests from a custody case]

 

33. That you and Plaintiff are the parents of [child]. 34. That you recently completed an application for food stamps. 35. That in that application for food stamp benefit, you indicated that you were homeless. 36. That you have a pending charge for possession of paraphernalia in Montgomery County, 37. That you are currently on probation for the assault conviction. 38. That you have a pending court hearing for a probation violation in Montgomery County. 39. That you have denied Plaintiff access to [child] since September 16, 2014.   Request for Admission of Facts & Genuineness of Documents Page 4 of 5

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40. That you use or have used marijuana. 41. That you were convicted of Assault in the 2nd degree against Plaintiff in June, 2011. 42. That as a result of that conviction, you were sentenced to three years prison time in the Maryland Department of Corrections. Respectfully submitted,

Atty. BUTCH BULALA  Counsel for the Plaintiff   Rooms 201 - 202, Aniceta Bldg  Osmena Blvd., Capitol Site 

Certificate of Service

I hereby certify that on this day of , , a copy of the foregoing Request for Admission of Facts and Genuineness of Documents was mailed, first class mail, postage prepaid, to [opposing counsel].

Atty. Glenford Catabian Counsel for the Defendant

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