ATTORNEY #12345

Utah County Public Defender’s Association

180 North University Ave., Suite 180

Provo, Utah 84601

Telephone: (801) 852-1070

e-mail address: Attorney@utcpd.com

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IN THE FOURTH DISTRICT JUVENILE COURT

UTAH COUNTY, STATE OF UTAH

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STATE OF UTAH In the Interest Of: DOE, JONNY 12-31-1999 Person under eighteen (18) years of age	MOTHER/FATHER’S FIRST SET OF REQUESTS FOR ADMISSIONS, INTERROGATORIES, AND REQUESTS FOR PRODUCTION OF DOCUMENTS Case No. ******* Judge Iron Man

The Mother/Father, by and through Counsel, Attorney, hereby requests pursuant to U.R.Juv.P. 20A and U.R.Civ.P. 26 that the Division of Child and Family Services (DCFS) produce the documents requested below and answer the Requests for Admissions and Interrogatories found herein within fourteen (14) days of receipt or service of this document:

I. DEFINITIONS AND INSTRUCTIONS

Unless otherwise defined in a specific admission, interrogatory, or request:

1.	“The child(ren)” refers to ____.

2.	“The mother” means _____.

3.	“The father” means _____.

4.	“Division” means the State of Utah, Division of Child and Family Services.

5.	“You” and “Your” refers to _____ or any agent acting on behalf of _____.

Instructions: Please take notice that failure to respond or object to any or all of the following requests for admissions results in an automatic admission of the same as a matter of law. U.R.Civ.P.36(b) “The matter is admitted unless […] the responding party serves upon the requesting party a written response”; See also State v. N.R. (state ex. rel. E.R.), UT 2000 UT App 143, ¶ 10, (“When requests for admissions are properly served, and no written answers or objection has been submitted, the result is automatic--the requests for admissions, as a matter of law, are deemed admitted by simple operation of the rule.”)

II. REQUESTS FOR ADMISSIONS

REQUEST FOR

ADMISSION 1:	Admit that

REQUEST FOR

ADMISSION 2:	Admit that

REQUEST FOR

ADMISSION 3:	Admit that

REQUEST FOR

ADMISSION 4:	Admit that

REQUEST FOR

ADMISSION 5:	Admit that

REQUEST FOR

ADMISSION 6:	Admit that

REQUEST FOR

ADMISSION 7:	Admit that

REQUEST FOR

ADMISSION 8:	Admit that

REQUEST FOR

ADMISSION 9:	Admit that

REQUEST FOR

ADMISSION 10:	Admit that

REQUEST FOR

ADMISSION 11:	Admit that

REQUEST FOR

ADMISSION 12:	Admit that

REQUEST FOR

ADMISSION 13:	Admit that

REQUEST FOR

ADMISSION 14:	Admit that

REQUEST FOR

ADMISSION 15:	Admit that

REQUEST FOR

ADMISSION 16:	Admit that

REQUEST FOR

ADMISSION 17:	Admit that

REQUEST FOR

ADMISSION 18:	Admit that

REQUEST FOR

ADMISSION 19:	Admit that

REQUEST FOR

ADMISSION 20:	Admit that

III. INTERROGATORIES

INTERROGATORY NO. 1:

In the event your responses to any of the Requests for Admission propounded herein are anything but unqualified admissions, state with specificity and in detail wherein you claim the admissions are in error and what you claim to be the true facts in regard to these admissions, stating with specificity and in detail the reasons for the denial or set forth in detail the reason why the answering party cannot truthfully admit or deny the matter. If the answering party denies any matter herein based on lack of information or knowledge, state what inquiries were made to gain the information sought.

INTERROGATORY NO. 2:

Identify each and every person who assisted in answering these Requests for Admissions, Interrogatories, and Requests for Production of Documents.

INTERROGATORY NO. 3:

Identify each and every person whom you intend to call as a witness, including expert witnesses, at the time of trial and set forth a factual summary of his or her expected testimony.

INTERROGATORY NO. 4:

INTERROGATORY NO. 5:

INTERROGATORY NO. 6:

INTERROGATORY NO. 7:

INTERROGATORY NO. 8:

INTERROGATORY NO. 9:

INTERROGATORY NO. 10:

INTERROGATORY NO. 11:

IV. REQUEST FOR PRODUCTION OF DOCUMENTS

REQUEST 1:	Produce each and every document identified in each of your responses to the request for admissions or interrogatories herein.

REQUEST 2:	Produce each and every document that supports any of the facts contained in your responses to the requests for admissions and interrogatories.

REQUEST 3:	Produce each and every document upon which you relied in order to answer any interrogatory or request for admission.

REQUEST 4:	Produce each and every document upon which any witness will rely on for their testimony at trial.

REQUEST 5:	Produce each and every document that you intend to introduce as an exhibit at trial.

REQUEST 6:

REQUEST 7:

REQUEST 8:

REQUEST 9:

REQUEST 10:

DATED this 31st day of December 1999.

___/s/ Attorney____________

ATTORNEY NAME

Utah County Public Defender Association