Form 18-12

For a general discussion of the action on a lease of personal property, see section 14.26 in this manual.

Pattern Requests for Admissions—Lease of Personal Property

1.Admit or Deny

that on or about [date], Plaintiff and Defendant entered into a written contractual agreement entitling Defendant to the use and enjoyment of [describe leased personal property] for an ini­tial period of [number] months.

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2.Admit or Deny

that the document attached as Exhibit [exhibit number/letter] is a genuine, true, and correct copy of the agreement referred to in request number 1.

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3.Admit or Deny

that the document attached as Exhibit [exhibit number/letter] contains all the terms and condi­tions agreed to by and between Plaintiff and Defendant with respect to the lease of the per­sonal property described in request number 1.

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4.Admit or Deny

that under the terms of the agreement referred to in request number 1., Defendant was obli­gated and bound to pay to Plaintiff the total amount of $[amount], which was to be paid in [number] equal monthly installments of $[amount].

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5.Admit or Deny

that Defendant has made only [number] of the monthly payments called for by the agreement referred to in request number 1.

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6.Admit or Deny

that the balance due to Plaintiff by Defendant under the agreement referred to in request num­ber 1. is $[amount] as of [date].

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7.Admit or Deny

that Plaintiff has declared Defendant to be in default under the terms of the agreement referred to in request number 1. and has called for the payment of the outstanding balance.

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8.Admit or Deny

that the agreement referred to in request number 1. was not subject to cancellation by any party except as expressly provided for in the agreement.

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9.Admit or Deny

that the Defendant acquired no right, title, or interest in the personal property described in request number 1. except as expressly stated in the agreement referred to in request number 1.

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10.Admit or Deny

that the property leased by Defendant under the agreement referred to in request number 1. has performed and operated in accordance with any representations or warranties made by or on behalf of Plaintiff with respect to the suitability or durability of the property.

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11.Admit or Deny

that Plaintiff performed all its obligations under the agreement referred to in request number 1.

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