Your guide to navigating discovery with uninsured motorist carriers

Download Our proven Sample UM discovery requests

Efficiently Gather Key Information: Targeted admissions and interrogatories enable you to thoroughly address every critical aspect of your case, from policy nuances to incident specifics.

Streamline Document Collection: Our request for the production of documents ensures comprehensive evidence gathering, enhancing the thoroughness and efficiency of your case preparation.

No Yarbrough Dismissals Until Discovery Is Complete

It's crucial to hold off on seeking a Yarbrough dismissal, as referenced in Yarbrough v. Dickinson, until the completion of discovery. Prematurely allowing a UM carrier to exit the case could mean overlooking vital discovery materials. UM carriers often possess critical information, such as photographs, videos, estimates, recorded statements, and signed selection rejection forms that can pivot the direction and outcome of a case. Ensuring comprehensive discovery before considering a Yarbrough dismissal is not just procedural; it's a strategic necessity for maximizing your client's claim potential.

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• Practical Application: Use these templates to refine your UM/UIM discovery approach, saving time and amplifying your case strategy’s effectiveness.
  

Don't let the complexities of cases involving UM/UIM carriers slow you down. Our expertly designed template is here to help you manage these cases more efficiently and effectively. Click below, provide your email, and get immediate access to this essential legal resource.

PREVIEW:

IN THE STATE COURT OF HALL COUNTY

STATE OF GEORGIA

JOHN BROWN,

PLAINTIFF,

v.

ROBERT SMITH,

DEFENDANT.

CIVIL ACTION

FILE NO.:

PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS, INTERROGATORIES, AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STATE FARM FIRE AND CASUALTY COMPANY

TO: State Farm Fire and Casualty Company, UM Carrier

FROM: John Brown, Plaintiff

ADMISSIONS

INSTRUCTIONS

a) The pronoun “you” and “your” refers to the party to whom the Admissions are addressed and includes knowledge of the party's agents, representatives, and unless privileged, their attorneys and any agents directing this defense on behalf of this party.

b) The term “car crash” is defined as the incident occurring on Saturday, June 5, 2021 between the parties in this action.

c) If objection is made, the answer shall specifically deny the matter or set forth in detail the reasons why the answering party cannot truthfully admit or deny the matter. When a general objection is made to a pleading or evidence as a whole, part of which is not subject to the objection, the entire objection fails in its office as a critic. McDaniel v. Pass, 130 Ga. App. 614, 203 S.E.2d 903 (1974). A general statement that the Defendant can neither admit nor deny, unaccompanied by reasons, will be held an insufficient response and subject to a motion to determine the sufficiency of the answer. It is not sufficient to limit answers to “for want of sufficient information”, the Defendant must provide what information is required to answer the pending request. Gregory v. Vance Publishing Corp., 130 Ga. App. 118 (1973).

d) Plaintiff reminds this party that Request for Admissions pursuant to O.C.G.A. §9-11-36 and Fed. R. 36 “are not objectionable even if [the admission] requires opinions or conclusions of law as long as the legal conclusion relates to the facts of the case.” G.H. Bass & Co. v. Fulton County Bd. Of Tax Assessors, 268 Ga. 327 (1997), Reversing G.H. Bass & Co. v. Fulton County Bd. Of Tax Assessors, 222 Ga. App. 118 (1996).

1. Admit this Defendant has been properly served with the summons and complaint as the underinsured/uninsured motorist carrier of the Plaintiff.
2. Admit this court has personal jurisdiction over this Defendant.
3. Admit this court has subject-matter jurisdiction in this case.
4. Admit venue is proper in this court.
5. Admit Plaintiff’s complaint alleges a specific amount of medical bills incurred because of the car crash.
6. Admit this Defendant does not have any defense based on insufficiency of process or insufficiency of service of process.
7. Admit Plaintiff’s complaint was filed before the expiration of the statute of limitations.
8. Admit this Defendant was served with a copy of the complaint prior to the expiration of the statute of limitations.
9. Admit this Defendant was properly named in the complaint.
10. Admit Plaintiff notified this Defendant of a potential claim as required by law and by the policy covering the Plaintiff.
11. Admit that the named Defendant Robert Smith is an uninsured or under-insured motorist as defined by Georgia law.
12. Admit that this defendant issued a policy of underinsured/uninsured motorist coverage covering the Plaintiff in the above-referenced matter in the amount of $25,000.00.
13. Admit that the policy(ies) referenced in the above request were valid and in effect at all times relevant to this litigation.
14. Admit that the policy(ies) referenced in the above request were of the add-on type.
15. Admit that Plaintiff has complied with all conditions precedent in recovering from their uninsured/underinsured motorist coverage.
16. Admit that this Defendant received....

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