Read the case study and then answer the questions that follow.

Case Study

Kirby is a personal trainer whose client list mainly consists of women in their 50s who want to tone up and slim down. Many of these women have done very little exercising before hiring Kirby. Because of this, Kirby asks detailed questions about their health before he creates an exercise plan for them.

Liza, a 54-year-old insurance actuary, has heard great things about Kirby from her friends. She makes an appointment to meet with him. As with all his clients, Kirby asks Liza about her health and any fitness training she might have had. Liza, trying to impress Kirby, says she's fit as a fiddlealbeit a little flabbywalks two miles a day, and does a little cardio. None of this is true. Liza has nagging pains in her knees, and she rarely even takes the stairs at work.

Kirby begins working with Liza and, based on her background, establishes a moderately difficult regimen for her. One week into training, Liza's knees go from nagging to throbbing pain, and within two weeks, she can barely walk from her car to her office. Liza thinks her knees should have gotten better, not worse, under Kirby's training if he were doing it right. She stops going to Kirby, stops paying the remainder of her contract, and decides to sue him for injury to her knees.

Kirby hires your law firm to represent him. He denies any liability for Liza's knee condition, and he wants payment for the remainder of her contract. You and your supervising attorney have completed most of the discovery for this case. Your attorney now asks you to draft a request for admission.

Your request for admission should include statements you know Liza may find objectionable because, if she admits to these statements, it will save your attorney a lot of hard work later.

a. True
b. False