Question: I need help writing a request for admission to the court. Witness Statement of Robert Warren I, Robert Warren, arrived at Maple Meadows Campground on
I need help writing a request for admission to the court.



Witness Statement of Robert Warren I, Robert Warren, arrived at Maple Meadows Campground on April 5, 2023, at around Noon. There were only a few other campers present. I chose campsite 34. I found the conditions to be warm, dry, and windy. I observed a young family arrive at the campgrounds around 1:00 pm. (I checked my watch). They set up in campsite 36. They had a newer camper (I think it was a Lance model), which was attached to a Ford F150. l was sitting in my chair relaxing and happened to watch some of the activities in the neighboring campsite. I observed a man set up the campsite while a woman unloaded something from the truck to bring to the camper. Their little boy, who appeared to be about six or seven years old, got very busy exploring, picking up things, etc. I enjoyed watching him because he reminded me of my grandson. After a while, I heard the man ask his wife something to the effect that he wondered why they had placed an electrical cord, and not a very good one, near a campsite where children might be playing. I had not noticed the cord until I heard him mention it. I saw him pick up what I assume was the cord and throw it back into the grass and brush away from where his son was playing. They were having difficulty with their electrical hookup. He came over to see me and asked if I was having difficulty with the electricity, and I told him that l was not. He said the light in their camper kept flickering on and off as did their radio. I remember the comment about the radio because I do not like radios in campgroundsl think it's rude. The man introduced himself as Carl. Later, I noticed Carl's boy playing further back in the grass and bushes. I saw light flicker briefly and assumed the boy was playing with a sparkler like they do on the Fourth of July. It didn't occur to me that it might be the cord. Anyway, Carl and his wife seemed distracted and were not watching their child very closely. Carl and his wife had beers in their hands, but they did not appear inebriated. Around that time, I went into my camper grab a beer of my own, and then heard a child's screams. When I looked out my door I saw the brush behind Carl's campsite was ablaze and the wind was spreading the fire. Then I was shocked to see the boy in the middle of the fire. Carl threw a blanket over himself and ran into the fire to save his son. When Carl emerged, his son was wrapped in a blanket that was on fire. Carl's wife pulled the blanket from her son and used another blanket to smother the ames on Carl's clothes. I ran over with my small fire extinguisher, but it was nearly useless. Carl's face appeared to be burned on the left side, as did his arms and legs. By this time, a couple other campers came to help, as did Leroy, the manager of the campground. A camp maintenance worker, whose name I can't remember, offered to take Carl to the hospital in nearby Seattle. Carl's wife and her son followed them in their truck. It was not long before I realized that the fire was completely out of control. | hurried to my vehicle and retreated to the entrance of the camp. About 20 minutes later, fire trucks noticed Carl's boy playing further back in the grass and bushes. I saw light flicker briefly and assumed the boy was playing with a sparkler like they do on the Fourth of July. It didn't occur to me that it might be the cord. Anyway, Carl and his wife seemed distracted and were not watching their child very closely. Carl and his wife had beers in their hands, but they did not appear inebriated. Around that time, I went into my camper grab a beer of my own, and then heard a child's screams. When I looked out my door I saw the brush behind Carl's campsite was ablaze and the wind was spreading the fire. Then I was shocked to see the boy in the middle of the fire. Carl threw a blanket over himself and ran into the fire to save his son. When Carl emerged, his son was wrapped in a blanket that was on fire. Carl's wife pulled the blanket from her son and used another blanket to smother the ames on Carl's clothes. I ran over with my small fire extinguisher, but it was nearly useless. Carl's face appeared to be burned on the left side, as did his arms and legs. By this time, a couple other campers came to help, as did Leroy, the manager of the campground. A camp maintenance worker, whose name I can't remember, offered to take Carl to the hospital in nearby Seattle. Carl's wife and her son followed them in their truck. It was not long before I realized that the re was completely out of control. | hurried to my vehicle and retreated to the entrance of the camp. About 20 minutes later, fire trucks arrived and eventually gained control of the fire. Several small buildings and a lot of the campground was burned. Thinking back, I would say the cause of the fire must have been the electricity problem. The brief flashes that I saw were probably some sort of electrical short-circuit. I say this, because Carl told me he was having trouble with his lights and radioalso because of where the fire started, which was in the same area where Carl had tossed the cord. I declare under penalty of perjury that the above mentioned facts are true and accurate to the best of my knowledge and recollection. Dated: May 9, 2023. mew RESPONSE: REQUEST FOR ADMISSION NO. 2: SUPERIOR COURT OF WASHINGTON RESPONSE: THE COUNTY OF KING CARL AMECHE AND ZOE AMECHE ) No. 23-2-11124-7 SEA 10 HUSBAND AND WIFE, AND THE 10 REQUEST FOR ADMISSION NO. 3: ) REQUESTS FOR ADMISSION 11 MARITAL COMMUNITY COMPOSED THEROF, 11 12 12 Plaintiffs, 13 13 RESPONSE: 14 14 LEROY CONGDEN, 15 15 Defendant. 16 16 REQUEST FOR ADMISSION NO. 4: 17 TO: Leroy Congden, Defendant; 17 18 AND TO: Sal Minella, Counsel of Record. 18 19 You are served with the original and one copy of the [party]'s [specify number. 19 RESPONSE: 20 e.g., First] Set of Requests for Admission pursuant to CR 36. Please type your responses in the 20 21 space provided and if necessary, add additional pages. Return the verified original of the 21 22 completed Requests for Admission to [set out the name and address of the requesting party's 22 REQUEST FOR ADMISSION NO. 5: 23 attorney of record] within 30 days after service of these requests. 23 24 REQUEST FOR ADMISSION NO. 1: 24 25 25 Requests for Admission Requests for Admission Page 1 Page 2
Step by Step Solution
There are 3 Steps involved in it
Get step-by-step solutions from verified subject matter experts
