PENNSYLVANIA:
IN THE COURT OF COMMON PLEAS FOR VENANGO COUNTY
ERIC J. BONETTI, Plaintif,
CIVIL ACTION NUMBER: 806-2020
vs. ROBERT H. MALM, Defendant
PLAINTIFF’S REQUESTS FOR ADMISSION COMES NOW Plaintif, ERIC J. BONETTI, in the above-titled action and, pursuant to the Rules of the Supreme Court of Pennsylvania, and hereby requests that Defendant, ROBERT H. MALM, admit or deny the truth/accuracy of the following: 1. That Robert H. Malm was aware at all relevant times that Sigrid Yahner was terminally ill. 2. That Robert H. Malm failed to secure leave of court as required by Pennsylvania law prior to his eforts to subpoena Ms. Yahner. 3. That Robert H. Malm falsely claimed that Ms. Yahner contacted him repeatedly to set up appointments, only to cancel. 4. That Robert H. Malm was represented by counsel at the time he made his false statement that Ms. Yahner contacted him repeatedly to set up appointments, only to cancel. 5. That Robert H. Malm made his false statement that Ms. Yahner contacted him repeatedly to set up appointments, only to cancel, in writing and under oath. 6. That Robert H. Malm has no evidence to support his claim that Ms. Yahner contacted him repeatedly to set up appointments, only to cancel. 7. That Robert H. Malm made false statements in conjunction with his eforts to obtain a protective order against Plaintif.
Respectfully submitted, ERIC BONETTI Pro Se Plaintif 4129 Fountainside Lane 203 Fairfax VA 22030 Eric.bonetti@me.com
CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was emailed and mailed, via USPS First Class mail, to Counsel for Defendant on Monday, September 20, 2020 per the following: Rachel Wenger, Esq. Cozen O’Connor One Oxford Centre 301 Grant St 41st floor Pittsburgh, PA 15219 Email: rwenger@cozen.com Phone: +1(412)620-6547
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ATTEST: COMMONWEATH/STATE OF _______________ COUNTY OF _______________________ I, ________________________, a Notary Public in and for the County and Commonwealth/State aforesaid, whose commission expires on the ___ day of _____________, 20___, do hereby certify that _______________________, whose name(s) is/are signed to the foregoing writing bearing date of the ___ day of ___________, 20___, has acknowledged the same before me in the County and Commonwealth/State aforesaid. GIVEN UNDER MY HAND THIS ___ day of _______________, 20___. ________________________ NOTARY PUBLIC My commission expires: ____________________________ Notary Registration Number: ________________________ NOTARIAL SEAL REQUIRED
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