Request for Admissions

You are tasked with drafting a comprehensive Request for Admissions, a critical discovery document used in litigation to narrow issues, establish uncontroverted facts, and authenticate documents. This document must comply with applicable procedural rules, typically Federal Rule of Civil Procedure 36 or state equivalents, and should be strategically crafted to advance the requesting party's case theory while meeting all technical requirements.

Before beginning the drafting process, conduct a thorough review of all case-related documents that have been uploaded to identify specific facts, dates, names, amounts, events, and documentary evidence that should form the basis of your admission requests. Extract concrete details including party names, relevant dates and timelines, monetary amounts, contractual provisions, communications, and any exhibits or documents referenced in the pleadings or discovery materials. This factual foundation is essential to crafting specific, targeted requests rather than generic or speculative ones. Pay particular attention to facts alleged in the complaint or answer, matters raised in initial disclosures, and any documents exchanged during discovery that require authentication.

Begin by creating a proper caption and header that identifies the court, jurisdiction, case title with all parties listed as they appear in the complaint, complete docket number, and designation of which party is filing the request. The caption must conform to local court rules and formatting requirements specific to the jurisdiction. Ensure the header clearly designates this as a "Request for Admissions" and identifies both the propounding party and the responding party with precision. Include any case management track designation or judge assignment if required by local practice.

Draft an introduction that formally identifies the requesting party and the party from whom admissions are sought, using their full legal names as they appear in the pleadings. Explicitly state that these requests are made pursuant to the applicable procedural rule, citing the specific rule number whether Federal Rule of Civil Procedure 36 or the relevant state equivalent such as California Code of Civil Procedure section 2033.010 or Texas Rule of Civil Procedure 198. Include a brief statement explaining that these requests are designed to narrow the issues for trial, establish uncontroverted facts, and authenticate documents relevant to the claims and defenses in this litigation. This introduction establishes the legal foundation and authority for the requests while providing context about their strategic purpose in the case.

If the requests will employ specialized terminology, industry-specific language, legal terms of art, or case-specific concepts that require clarification, include a definitions section immediately following the introduction. Define only those terms that are essential for clarity and that will be used repeatedly throughout the requests to avoid ambiguity. Each definition should be precise, unambiguous, and drafted to prevent disputes about interpretation. For example, if the case involves a construction dispute, you might define "the Project" to mean the specific construction work identified in the contract, or in an employment case, define "the Termination" to mean the specific date and circumstances of the plaintiff's separation. Consider whether definitions will genuinely aid understanding or might create unnecessary complexity that could provide grounds for objection. In many straightforward cases, definitions may be unnecessary and should be omitted to maintain simplicity.

Compose the substantive requests for admissions as separately numbered paragraphs, each containing a single, clear, and unambiguous statement for admission. Structure these requests strategically to address the three permissible categories under the applicable rules: first, the truth of specific facts relevant to the case; second, the application of law to fact where appropriate; and third, the genuineness of documents attached as exhibits. Each request must be drafted with surgical precision to elicit a clear admit or deny response without room for evasion or equivocation. Frame requests affirmatively when possible, stating what is true rather than what is not true, as this creates clearer admissions. Avoid compound requests that combine multiple facts into a single request, as these invite partial denials and create ambiguity. For example, instead of requesting "Admit that you received the notice on March 15, 2023, and failed to respond within thirty days," draft two separate requests addressing receipt and the timing of response independently.

Draw directly from the factual record you have reviewed to craft specific, concrete requests rather than generic templates. If the complaint alleges that the defendant sent a termination letter on a specific date, request admission of that fact with the exact date. If discovery has produced a contract, attach it as an exhibit and request admission of its genuineness and that it represents the agreement between the parties. If the answer admits certain allegations, consider whether requesting admission of those same facts will create a binding judicial admission that cannot later be withdrawn. Organize the requests in a logical progression, often beginning with foundational facts such as the existence of relationships, contracts, or events, then building to more specific facts about communications, actions, damages, or defenses. Consider grouping requests thematically by topic such as background facts, contract formation, performance, breach, causation, and damages.

Ensure each request serves a legitimate strategic purpose in the litigation. Prioritize admissions that will eliminate the need for proof at trial of foundational or uncontroversial matters, establish foundation for the admission of other evidence, authenticate documents you intend to use at trial, narrow contested issues to focus resources on genuine disputes, or undermine the opposing party's defenses or affirmative claims. Avoid requests that are harassing, overly broad, or seek admissions of purely legal conclusions such as "Admit that you breached the contract" or "Admit that you were negligent." While requests may address the application of law to fact, they should not ask the responding party to admit ultimate legal conclusions that are for the trier of fact to determine. Similarly, avoid requests that call for opinions, ask the responding party to admit matters within the requesting party's knowledge, or seek admissions about matters of public record that can be easily proven through other means.

Draft each request to be clear, specific, and fair. A well-crafted request should be one that a reasonable party would admit if true, deny if false, or explain why they cannot truthfully admit or deny based on lack of knowledge after reasonable inquiry. Avoid trick questions, double negatives, or deliberately confusing language designed to trap the responding party. While the requests should be strategically advantageous, they must maintain professional integrity and comply with the attorney's duty of candor. The goal is to obtain meaningful admissions that will streamline the litigation, not to create a document that invites wholesale objections or motions for protective orders.

For document authentication requests, attach each document as a separately labeled exhibit and request admission that the document is genuine and that it is what it purports to be. You may also request admission that the document was sent, received, signed, or executed by specific parties on specific dates if supported by the factual record. This is particularly valuable for contracts, correspondence, invoices, photographs, or business records that you intend to introduce at trial, as an admission of genuineness can eliminate the need for foundation testimony and streamline evidentiary presentation.

Following the numbered requests, provide clear and complete instructions for response that inform the responding party of their obligations under the applicable procedural rule. Specify that responses must admit each request, deny each request, or state in detail the reasons why the party cannot truthfully admit or deny the request, including specification of what part is admitted and what part is denied if the truth lies somewhere between a complete admission and complete denial. Include the deadline for response, typically thirty days after service under Federal Rule of Civil Procedure 36(a)(3), though this may vary by jurisdiction, local rule, or court order, and note that the time may be extended by written agreement or court order. Explicitly state the consequences of failure to respond within the time allowed, including that each matter for which a response is not served will be deemed admitted pursuant to the applicable rule. Reference the specific rule provision governing automatic admissions to emphasize the seriousness of the deadline.

Inform the responding party of their obligation under the rules to make reasonable inquiry and investigation before responding, and that lack of information or knowledge is not a valid basis for denial unless the party states that they have made reasonable inquiry and that the information known or readily obtainable is insufficient to enable them to admit or deny. Include a statement that the responding party has a continuing duty to supplement or correct responses if they learn that a response was incomplete or incorrect when made, or if they obtain information that makes the response incomplete or incorrect, citing the applicable supplementation rule. Advise that objections must be stated with specificity and that the grounds for objection must be clearly articulated, and that an objection does not excuse the party from responding to the portion of the request to which no objection is stated.

Conclude with a proper signature block that includes the attorney's full name, state bar number, law firm name, complete mailing address, telephone number, facsimile number if applicable, email address, and designation as "Attorney for [Requesting Party]." If the party is proceeding pro se, adapt the signature block to include the party's name, address, telephone number, and email address with designation as "Pro Se." Include a date line that will be filled in when the document is finalized and signed. Add any verification or certification statement required by local rules, such as a certification that the requests are made in good faith and are not interposed for any improper purpose such as harassment or unnecessary delay.

Include a certificate of service that certifies the date and manner of service on all parties or their counsel of record. Specify the method of service, whether by electronic filing and service through the court's electronic filing system, email, mail, personal delivery, or other means permitted by the applicable rules. List each party served, their counsel if represented, and the address or email address to which service was made. Include the signature of the attorney or party certifying service and the date of service. Ensure compliance with any local rules regarding the format and content of certificates of service.

Throughout the document, maintain a professional tone that is firm, clear, and businesslike but not argumentative, accusatory, or inflammatory. The requests should be drafted as neutral statements of fact for admission rather than advocacy or argument. Avoid editorial comments, characterizations, or language that appears designed to provoke or antagonize the responding party. The document should reflect the seriousness and formality of a court filing while remaining accessible and clear in its language. Each request should serve a legitimate discovery purpose and relate directly to claims or defenses properly at issue in the case as defined by the pleadings.

Format the entire document according to the court's rules regarding margins, spacing, font size and type, page numbering, and any other technical requirements. Many courts require specific formatting such as double-spacing, one-inch margins, and particular fonts. Ensure the document is well-organized with clear headings, consistent numbering, and professional appearance. The final document should be ready for attorney review, signature, filing with the court if required by local practice, and service on opposing counsel. Verify that all exhibits referenced in the requests are properly attached and labeled, and that all citations to rules and statutes are accurate and current.