I am serving interrogatories and request to the Defendant. I know attorneys try to not answer as much as possible and will claim a single question or request is more than one. Please consider this question and let me know if it is a single question:
1. If you contend that any additional part of the property, or it’s fixtures and/or apparatuses were damaged by Plaintiffs misuse, waste or neglect, specifically state what was damaged and state with particularity the facts upon which you base your contentions.
Also, let me know if the follow request for admission is a single admission:
1. Admit you are responsible for maintenance and repair of all major appliances, plumbing, range, heating, apparatus, and electric and gas fixtures whenever damage thereto did not result from misuse, waste or neglect by the Plaintiffs or Plaintiffs employee
, family, agent, or visitor.