If the defendant refuses to produce some of the written discovery you requested, you should initiate a meet-and-confer process. It is often helpful to use a combination of telephone calls and letters to conduct this process. The ouster of Fox's top . 21 0 obj<> endobj 0000011647 00000 n 0000001519 00000 n The number of updates may vary due to developments in the law and other publishing issues, but most of our titles are updated every 12 to 24 months. One wrinkle in ADEA cases is that the ADEA does not authorize mixed-motive discrimination claims (unlike Title VII claims, as discussed above). 2000e et seq. The Corporate Transparency Act and Beneficial Ownership Reporting Long COVID Presents New Challenges for Employers, No-Poach Agreement as Per Se Violations of the Antitrust Law. As the case proceeds and you gather evidence, update your discovery plan to see what you have obtained, what you are still missing, and whether you have learned of new topics of discovery that you had not been able to foresee at the outset of the case. 186, 18992 (D.N.J. In Title VII disparate-impact class actions, which allege that a facially neutral policy had a disparate impact on a protected category of employees, you will likely be entitled to information about the impact that the allegedly discriminatory policy had on the class. To find this article in Lexis Practice Advisor, follow this research path: RESEARCH PATH: : Labor & Employment > Discrimination, Harassment and Retaliation > Claims and Investigations > Practice Notes, For more information on plaintiff-side discovery in employment discrimination cases, see, > DEPOSING EMPLOYER WITNESSES: HOW TO PREPARE IN EMPLOYMENT DISCRIMINATION CASES (PRO-EMPLOYEE), RESEARCH PATH: Labor & Employment > Discrimination, Harassment, and Retaliation > Claims and Investigations > Practice Notes, For a discussion of deposition strategies in employment cases, see, > RULE 30(B)(6) DEPOSITION STRATEGIES FOR EMPLOYEE-PLAINTIFFS IN EMPLOYMENT CASES, For a sample document request form for use by plaintiffs counsel, see, > DOCUMENT REQUESTS (PLAINTIFF TO DEFENDANT) (SINGLE-PLAINTIFF DISCRIMINATION ACTION), RESEARCH PATH: Labor & Employment > Discrimination, Harassment, and Retaliation > Claims and Investigations > Forms, For a checklist to use in preparing a plaintiff for his or her deposition, see, > DEPOSITIONS IN EMPLOYMENT LITIGATION: PREPARING THE PLAINTIFF CHECKLIST (EMPLOYEE), RESEARCH PATH: Labor & Employment > Discrimination, Harassment, and Retaliation > Claims and Investigations > Checklists, > DISCOVERY PLAN (TITLE VIII DISCRIMINATION CASES (PRO-EMPLOYEE), > NOTICE OF DEPOSITION (FRCP RULE 30(B)(6)) (PLAINTIFF TO DEFENDANT), RESEARCH PATH: Labor & Employment > Employment Litigation > Discrimination, Harassment and Retaliation > Forms, For a guidance on complying with the ADEA, see, > AGE DISCRIMINATION IN EMPLOYMENT ACT (ADEA): KEY CONSIDERATIONS, RESEARCH PATH: Labor & Employment > Employment Litigation > Discrimination, Harassment, and Retaliation > Practice Notes, > AMERICANS WITH DISABILITIES ACT: EMPLOYER REQUIREMENTS AND REASONABLE ACCOMMODATIONS, For an analysis of potential joint employer relationship, see, > JOINT EMPLOYMENT RELATIONSHIPS: BEST PRACTICES AND RISKS, RESEARCH PATH: Labor & Employment > Screening and Hiring > Recruiting and Screening > Practice Notes, > 9 LARSON ON EMPLOYMENT DISCRIMINATION 152.08, RESEARCH PATH: Corporate Counsel > Labor and Employment Law > Employment Discrimination > Secondary Materials, 1. Each factual statement will form the burden of proof for your case. endobj Produce copies of all documents in the complainant's possession that pertain to his/her contention that So, if the opposing party admits to driving above the speed limit at the time of the accident, the court considers that statement a fact. For instance, if the Defendant was driving above the speed limit at the time of the accident and failed to slow down, causing the car accident that injured the Plaintiff, the Defendants speeding could be found as the proximate cause of the accident. 0000002551 00000 n 00D]L@l ` The Defendant is who the Plaintiff believes caused the injuries. Statistical proof is typically central to disparate impact claims, so plaintiffs have a strong claim for access to the data that will allow analysis of the impact of the policy at issue. 0000192395 00000 n See, e.g., Madrigal v. Allstate Indem. Discovery Plans. Like many states, Maryland follows Federal Rule of Civil Procedure 36(b), governing procedure regarding requests for admissions. endobj 0000002609 00000 n 0000115544 00000 n To that end, you can agree that the interrogatory responses will be covered by a stipulated protective order. REQUESTS FOR ADMISSIONS On September 22, 2002, you reassigned Mr. 0000100955 00000 n Requests for admission (RFAs) are an extremely valuable, but significantly underused, discovery and litigation tool. 0000009965 00000 n You may have heard that depositions are the driving force of a personal injury lawsuits discovery process. How to Respond to RFAs. He has experience prosecuting class actions and employment claims and handling high-stakes commercial disputes and appeals. Courts often apply the proportionality limit by striking a compromise between the two parties positions. If the CEO has personal knowledge of facts relevant to the case, you should be able to take the deposition. Entering into such an agreement early on can prevent delays in production of the information. @ 3012I00b%3n ` LEXIS 29441, at *5 (D. Conn. Mar. [Sb0e$Hv`L}E vss6 KR4b.-V8Ai2^TF at 4748. 0000000616 00000 n Since 1981, James Publishing has provided practical law books that are loaded with time-saving motions and pleadings, client letters, and step-by-step procedural checklists, pattern arguments, model questions, pitfalls to avoid, and practice tips. 0000006790 00000 n Discrim. 0000005587 00000 n 20. ADMISSIONSUSE WITH DOCUMENT REQUESTS 1. 0000155401 00000 n See, e.g., Welch v. Eli Lilly & Co., 2008 U.S. Dist. Counsel should consider requests for admissions but must keep in mind that these are answered by the plaintiff's attorneys. However, Bacon clearly establishes that the same type of evidence that would support a "pattern or practice" allegation in a class-action case will usually be admissible in an individual case. 0000003004 00000 n 0000003091 00000 n <<5180521631658541a40443d85a3da2d8>]>> Plaintiff, therefore, has admitted the following facts: She was not the subject of unwelcome harassment at any point during her employment with Fidelity Mortgage, Inc. She was not subjected to unwelcome sexual advances, requests for sexual 2015) (affirming lower courts decision to limit discovery into age discrimination case by location and job title). x%0WdHHh" See, e.g., C.D. 1. Apr. Proc., 2030.010, subd. 0000104832 00000 n Address: 2005 N. Central Avenue, Phoenix, AZ 85004. See, e.g., Harris v. Harley-Davidson Motor Co. Operations, Inc., 2010 U.S. Dist. %PDF-1.5 % 10. Keep this distinction in mind when creating your discovery plan. These include requests related to discoverable facts, opinions, the application of the law to facts, and the genuineness of documents. Interrogatories are useful, particularly early in the case, for identifying witnesses to depose or interview. Coord. 0000010134 00000 n %%EOF 246 0 obj <>stream ADOA Human Resources . 0000011285 00000 n Moving to Compel Further Responses to Written Discovery. Among the information sought was interrogatory: 0000067168 00000 n 100 North Fifteenth Avenue, Suite 301. See, e.g., Chen-Oster v. Goldman, Sachs & Co., 293 F.R.D. REQUEST FOR ADMISSION NO. Federal Court Proceedings II. 8 0 obj <>stream x%@F~/Xwfdkad This Information Collection Request is the reauthorization of OFCCP's complaint program. 16, 2008) (where defendant produced information pertaining to 5,000 potential comparators, court was unwilling to order production pertaining to defendants 21,000-person national workforce, but suggested that such a step might be justified if the plaintiffs came forward with evidence from the initial production that supported their claim of a discriminatory pattern or practice). 0000226717 00000 n Loc. 0000004021 00000 n The length of time available to file a complaint with the Attorney General's Office varies depending on the area of discrimination. 12 16 Based on privacy grounds, courts will be wary of disclosing information about the reasonable accommodation requests of other employees, but such information may be obtainable, potentially on an anonymized basis.28. 0000001216 00000 n 0000014768 00000 n Discrim. 8k''wnf>E>>qtqulrt6iS|oc_a\ksG_5|exI]9^SM :U^kzOuJ|([K%r\!2"o;;s L!a4{yLazGzGzGzGzGz={ When a plaintiff files an employment discrimination suit, "the charging . Courtstend to protect upper-level management from speculative depositions.27, In discrimination cases under the Americans with Disabilities Act (ADA) in which plaintiffs challenge the failure to provide a reasonable accommodation, plaintiffs must prove that with a reasonable accommodation, they could have performed the essential functions of the job in question, and that the employer refused to make such accommodations. Requests to admit can be served at any time, even as early as the complaint initiating the lawsuit. R. Civ. The article addresses how to use the different mechanisms for obtaining discovery effectively. All rights reserved. 0000001151 00000 n If the defendant objects to the scope of the topics in such a way that you will not be able to obtain important testimony, you can either seek a ruling on the objection before the deposition or hold the deposition open pending a ruling on the objection. May 22, 2017). 0000002140 00000 n 0000002594 00000 n For additional helpful interrogatories to consider asking, California provides so-called form interrogatories specific to employment cases, and although the form itself can be used only in California state courts, it may provide helpful ideas for interrogatories in federal cases.17. endstream 0000005473 00000 n 2, 2017) (to professor claiming discrimination in denial of tenure, court granted discovery into comparator evidence for professors seeking tenure in the same year, but otherwise denied discovery based on likelihood of annoyance [or] embarrassment under Rule 26(c)). . 0000224128 00000 n 0000001141 00000 n 0000021387 00000 n 0000004294 00000 n RESPONSE TO REQUEST FOR ADMISSION NO.1: Respondents object to the term "relevant service" to the extent that it implies a legal No claim to original U.S. Government Works. Avoid resting objections solely on the wording or form of the request. If a defendant fails to make an admission when requested, and the plaintiff later proves that the admission was true or the document genuine, the court may award sanctions.18. If you receive unverified responses, you should insist upon verification. Uninsured & Underinsured Motorist Accidents. For example, in a termination case, you should seek the names and contact information of each person involved in the decision to terminate your clients employment. %%EOF H\_k@|ylJbDuh25 1>wNN 0000006763 00000 n 14 0 obj<>stream 0000060329 00000 n Pa. Nov. 10, 2010) (requiring defendant to answer interrogatories identifying similarly situated employees who also complained of harassment, and to produce the portions of those employees personnel files relating to the complaint and defendants response, while redacting confidential and private information); Metcalf v. Yale Univ., 2017 U.S. Dist. hb```b``c`c``d@ AV(MM]E8t1 3fE3X+1ih2X0x3u`@'T8c W+&,:{qn'&?K2I:LSi9b#V _h;Ao See id. 0000010154 00000 n By doing this up front, you will avoid realizing long into the case that you have failed to request discovery on a topic that is important to your case. Confirm you were under the care of a physician at the time of the occurrence. REQUESTS FOR ADMISSIONS NOT RELATED TO THE GENUINENESS OF DOCUMENTS Request No. Your response(s) and the documents are to be sent to the undersigned at 104 Church Lane Suite 201, Baltimore, Maryland 21208. Admit you consumed drugs, medicines, or alcoholic beverages within twenty-four (24) hours prior to said occurrence. 2000e-5(g)(2)(B). By signing a request, you are certifying that the request is not unreasonable or unduly burdensome. A hearing provides the parties with a fair and reasonable opportunity to explain and supplement the record and, in appropriate instances, to examine and cross-examine witnesses. If the investigation was conducted by human resources personnel, or was not conductedbecause of litigation but merely as part of a human resources investigation, a court may hold that it is not privileged at all.1, Second, even if responsive documents are privileged, the defendant likely will have waived the privilege if it is asserting a Faragher/Ellerth affirmative defense. The answer will give you a target to attack, both in depositions and in further written discovery, in attempting to rebut the defendants claim that it would have terminated the plaintiff even absent any unlawful motive.15 Likewise, if you suspect that the defendant may assert that it would have fired the plaintiff anyway based upon facts it learned after the termination,16 ask the defendant to state any facts that would support the employees termination that it discovered after the termination. Both parties may send each other requests for admission. Phoenix, AZ 85007. 0000000016 00000 n See Chen-Oster v. Goldman, Sachs & Co., 293 F.R.D. HWmsFN NkgNGQ%* {;!DH#yxn!MGoTt5>oB!L.b|4!^B#+!Gc#jZXU5rEUB'kpNM$A\cZgU^ }PHp|\D\K^>'^x%Ol9c10;o=0^/;pHBCCto/og7S_]]Of-(\XTv UN#9.XE[+$x+"mnj(-Z]p. 0000013821 00000 n If the court finds that this rule has been violated without substantial justification, it is required to impose a sanction under Rule 26(g). 0000002732 00000 n See, e.g., C.D. A defendant will likely raise proportionality as an objection to requests for evidence of other similar allegations of discrimination or harassment made by employees of the defendant other than the plaintiff. 2000e et seq. Spring 2023 Graduates: Applications Open for New Loan Repayment Program for Students Earning a B.A. endstream endobj 202 0 obj <>>>/Metadata 199 0 R/Names 203 0 R/Outlines 160 0 R/Pages 195 0 R/Type/Catalog/ViewerPreferences<>>> endobj 203 0 obj <> endobj 204 0 obj <>/ExtGState<>/Font<>/ProcSet[/PDF/Text]/XObject<>>>/Rotate 0/Tabs/W/Thumb 175 0 R/TrimBox[0.0 0.0 612.0 792.0]/Type/Page>> endobj 205 0 obj [206 0 R 207 0 R 208 0 R] endobj 206 0 obj <>/Border[0 0 0]/H/N/Rect[353.326 442.25 532.909 430.384]/Subtype/Link/Type/Annot>> endobj 207 0 obj <>/Border[0 0 0]/H/N/Rect[538.291 372.25 576.0 360.384]/Subtype/Link/Type/Annot>> endobj 208 0 obj <>/Border[0 0 0]/H/N/Rect[338.0 359.25 514.198 347.384]/Subtype/Link/Type/Annot>> endobj 209 0 obj <> endobj 210 0 obj [/ICCBased 219 0 R] endobj 211 0 obj <> endobj 212 0 obj <> endobj 213 0 obj <> endobj 214 0 obj <>stream During discovery, the Plaintiff (typically the injured party) and the Defendant (the alleged at-fault party) attempt to uncover as much information about the case as possible. 2013). 0000138731 00000 n Aside from Admit or Deny, there is the option to Partially Deny a statement. Throughout a personal injury case, the Plaintiff and their legal team send requests for admission to the Defendant, in hopes the answering party will admit their wrongdoing. The facts in your case may be different too. 0000003198 00000 n Continuing with the auto accident personal injury example, the Defendants requests for admission may include: Confirm the only witnesses to the accident were the Plaintiff, Defendant, and an unidentified man who let the Plaintiff use his cell phone at the scene of the accident. 26. These answers are legally binding, and the opposing party must answer them truthfully or run the risk of committing perjury. 0000003473 00000 n Serve document requests early in the caseyou will need the evidence to depose witnesses, to prepare your witness to be deposed, and to determine what additional discovery to request. The outer limit of permissible discovery in any federal case is set by Federal Rule of Civil Procedure 26(b), which permits parties to obtain discovery regarding any nonprivileged matter that is relevant to any partys claim or defense and proportional to the needs of the case. The rule contemplates three limits on the scope of discovery: privilege, relevance, and proportionality. endstream 2013). Letters allow you to keep track of what has been discussed or agreed in the phone calls, and provide a record that you can useif you need to file a motion to compel the defendant to produce additional information. a list of who has the evidence. Bear in mind, if a party receives a request for admission that includes the mention of a document, federal rules dictate the production of documents for confirmation. This is not to say that either party is intentionally lying, but rather, each individual has a different perception of the same event. His practice seeks to represent plaintiffs and defendants in a range of civil litigation. R. Civ. 0000219541 00000 n For example, in a class action gender discrimination case, you may be able to obtain information pertaining to all the class members.10 In drafting discovery requests and in meeting and conferring over them, keep in mind that the broader the time period and geographic scope that your request covers, the more likely that a court will impose limitations due to proportionalityconcerns. 2009) (It is very unusual for a court to prohibit the taking of a 19. Appx. 24: Title VII Discrimination Defendant's Questions for Plaintiff FORM NO. endstream What can you do if an employer says they have video evidence? Co., 513 U.S. 352, 362 (1995). If you plan to submit to the court information that has been designated confidential, you will need to follow the appropriate procedure in that court for filing documents under seal, which may require some advance planning. Request for Admissions is a common request in the Discovery process of a lawsuit. As with document requests, word the interrogatories extremely carefully to make sure that the defendant cannot interpret them more narrowly than you intend. If you do not engage in a meaningful meet-and-confer process before filing a motion to compel, the court may require further meeting and conferring before issuing a decision. endobj x%0>7P{oNbJHT%q%=i`^-[!"a. Hearings are governed by 29 C.F.R. method of proving discrimination in class-action employment discrimination action is not available to an individual plaintiff. endstream endobj 15 0 obj <> endobj 16 0 obj <> endobj 17 0 obj <>stream Requests for admission and interrogatories fall under the same umbrella of discovery. For example, depending on the court, you may need to file a motion for leave to file documents under seal. Chen-Oster, at 565. The information that you provide is subject to MEL's Privacy Policy. 0000192356 00000 n Do not disclose personal identifying information except to the extent necessary to Ask MEL a question. AGE DISCRIMINATION 1. P. Rule 26(b)(1). 0000000016 00000 n 0000007709 00000 n Requests for Admissions Under the Civil Rules, one party can ask another party to a lawsuit to admit: the truth of facts relevant to the case, the application of law to fact, opinions about the facts or the application of law to facts, or the genuineness of documents. One way for an individual to stand up for themselves in court is to send requests for admission to the Plaintiff. Requests for admission are written requests that require a party to either admit or deny certain facts. endstream That the Complaint attached hereto and marked as Exhibit A is a true copy of the Complaint which was filed in a proceeding styled "_____ v. _____ in the Circuit Court, State of Alabama, _____ Judicial Circuit, Case No. 0000105192 00000 n See, e.g., Koumoulis, 295 F.R.D. endobj Mr. Audet has been recognized by Super Lawyers as one of the Top 100 Attorneys in Northern California. opinions about the facts or the application of law to facts, or. 0000001736 00000 n You should generally use document requests to obtain documents concerning: Unlike document requests, interrogatories in federal court are limited to 25 per party unless the court grants leave to propound more. ANSWER: The company then has an obligation to prepare the witness to speak about those topics. startxref 0000011029 00000 n R. 37-1, 37-2. deposition altogether and absent extraordinary circumstances, such an order would likely be in error.) (internal citation omitted). For instance, the responding party may partially deny a statement that accuses them of reckless driving if they were only driving 5 miles above the posted speed limit at the time of the accident. 0000115295 00000 n The witnesss testimony, if it is within the noticed topics, will be binding on the company. A9?L1A;%C^D:_ECg+m4pXo{pi)TnJtTF Requests for admission are written requests sent during the discovery process of a lawsuit. 1989); but see Conti v. American Axle and Manufacturing, 326 Fed. Two other important limits are the privacy interests of other employees and the bases for obtaining a protective order against discovery under Rule 26(c). Cal. UNITED STATES' FIRST REQUEST FOR ADMISSIONS,SECOND SET OF INTERROGATORIES ANDSECOND REQUEST FOR PRODUCTION OF DOCUMENTSTO CLARKE CONTAINER, INC. Pursuant to Rules 26, 33, 34, and 36 of the Federal Rules of Civil Procedure, Plaintiff, the United States of America, requests that Defendant Clarke Container, Inc. ("Clarke Container"): DOWNLOAD REQUEST FOR ADMISSIONS SAMPLE 2017 U.S. Dist. The Corporate Transparency Act They are an effective tool to help you streamline your case or defense. 0000006628 00000 n Thus, as in a Title VII case, discovery necessarily involves inquiring about the circumstances of other employees. startxref As a general rule, federal courts balance the plaintiffs need for the discovery against the strength of the privacy interest of other individuals. 0000156153 00000 n 0000003875 00000 n %%EOF endstream endobj 215 0 obj <>stream n%1$rA4nzJ$$8UD. 0000003746 00000 n William Audet and Kimberly Fanady offer you these tips from their book, Handing Federal Discovery, for propounding and responding to RFAs. 0000059409 00000 n LEXIS 77648, at *3 (N.D. Cal. Based on proportionality concerns, the court limited production to all sexual harassment or gender discrimination complaints filed about any person working in the same office as the plaintiff, and any settlement agreements related to that office that did not contain confidentiality provisions, with the names of the complainants to be redacted.9. 0000043713 00000 n of Columbus, 879 F.2d 212, 218 (6th Cir. 7. 0000010683 00000 n 0000005436 00000 n A request for admission (also called a request to admit) is a written statement sent from one party to the other. 107 0 obj <> endobj In particular, requests for admission are incredibly helpful in uncovering crucial information before either party takes the witness stand. 12 0 obj<> endobj 0000004801 00000 n D-1. treatment discrimination, the courts apply the paradigm set forth in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Note that some practitioners mistakenly argue that any information that is reasonably calculated to lead to admissible evidence is discoverable. Client. If you deny, in whole or in part, Request for Admission No. You nevertheless have a good chance of obtaining such information, because many courts have held that evidence of systemic discrimination in a workplace is probative of an individuals claim of discrimination, even if the plaintiff is not claiming that the employer engaged in a pattern or practice of this kind of unlawful conduct.22, In class discrimination cases, you will be able to obtain broader information than in an individual case.23 In addition, if you have a need to contact the individuals who made complaints in order to investigate the claims, you should seek unredacted versions of the complaints.24 If you are asserting a company-wide claim, you may obtain company-wide discovery if you are able to plead in the complaint, or gather facts to demonstrate, that the practice you are challenging did, in fact, apply company-wide, regardless of different business units, regional management teams, and the like.25 Still, courts will balance the plaintiffs need for the discovery with the burden on the defendant.26. <]>> ).14 The undue burden and oppression factors call for the same type of analysis as the proportionality requirement. If your case is likely to involve the records of other employees, or records of your own client that are sensitive and should be kept confidential, propose to the defendant early on that you enter into a stipulated protective order that requires the parties to maintain the confidentiality of private information produced in discovery. Can my employer record my Cell phone conversation? Federal Level - Equal Employment Opportunity Commission (EEOC) 15. hb```f``b m\,/80`@Pfa`>A \] The purpose of a request for admission is to identify and narrow down the genuine issues of what occurred, as these events will inform the verdict of the case. Make this demand in your discovery requests, and if the defendant does not provide a satisfactory log with its discovery responses, renew the demand through meet-and-confer discussions right away. Phone calls allow you to get a sense of the real basis of the defendants objections and where the defendant (and you) may be willing to compromise. The defendant, _____, requests the plaintiff to admit the following facts: 1. 24A: Title VII Discrimination Defendant's Questions for Plaintiff's Economic Expert Background FORM NO. Your deposition notice must include a list of the topics about which you wish to question the witness. Be careful not to waste them. See Fed. %PDF-1.7 % 2 0 obj <>stream See 42 U.S.C.S. The law in your state may be different from that discussed here. The proportionality analysis in a class case will allow the plaintiff to discover a much broader range of information. 27. endstream endobj startxref See Form Interrogatories Employment Law https://www.courts.ca.gov/documents/ disc002.pdf. Requests for admissions are a convenient way for each party to admit or deny allegations brought against them. 0000004771 00000 n 0000139632 00000 n Your complaint will need to be filed with the appropriate state or federal entity, as follows: State Level - Arizona Attorney General (AG), Civil Rights Division. The Factors That Justify a Protective Order Limiting Discovery under Rule 26(c). Fax (main): 602-542-3712. Cal. The Tech Law Awards, given By: Jonathan B. Wilson TAYLOR ENGLISH DUMA LLP AND THE FinCEN REPORT COMPANY 217.0 Response to Request for Admissions (f) ADVERSE EMPLOYMENT ACTION means any TERMINATION, suspension, demotion, reprimand, loss of pay, failure or refusal to hire, failure or refusal to promote, or other action or failure to act that adversely affects the EMPLOYEE'S rights or interests and which is alleged in the PLEADINGS. 0000002370 00000 n Agency will most likely serve the discovery requests to you, the Complainant (EEOC) or the Appellant (MSPB). You may also include the Request for Admission. 2016 U.S. Dist. If no responses are submitted within the timeframe, then all statements included in the request are deemed admitted by the court. Sept. 16, 2016). For instance, Plaintiff may assume no fault in an accident.
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