John O’Toole (Partner-Madison, NJ) and Kristine Pegno (Associate-Madison, NJ) obtained summary judgment in the Superior Court of New Jersey – Camden County for Wilson Elser’s client, a national property management company. The plaintiff alleged injuries resulting from a fall on our client’s property. The complaint identified the client’s apartment complex as the location of the fall. Still, the answers to interrogatories were ambiguous and suggested a site that was not a part of the subject premises. This uncertainty prompted John and Kristine to carefully craft requests for admissions, a little- used but valuable discovery tool, forcing the plaintiff to admit that the address where the injury occurred was not on our client’s property. Based upon the plaintiff’s admissions, John and Kristine filed a motion for summary judgment, arguing that Wilson Elser’s client owed no duty of care to the plaintiff as a matter of law. The court agreed and dismissed the complaint in its entirety.