Request for Admissions

Request for Admissions

Drafts FRCP 36 / state-equivalent Requests for Admissions that narrow trial issues, establish uncontroverted facts, and authenticate documents.

Prerequisites

Collect before drafting:

• Pleadings — complaint, answer, party names as captioned, docket number, court, judge
• Case documents — contracts, correspondence, medical records, invoices, photos for authentication
• Prior discovery — initial disclosures, interrogatory responses, document productions
• Jurisdiction — federal (FRCP 36) or state rule (e.g., CA CCP §2033.010, TX TRCP 198)
• Local rules — formatting, page limits, RFA number caps (many jurisdictions cap at 25–35)

Quick Start

1. Extract key facts from uploaded documents (names, dates, amounts, exhibits)
2. Draft numbered requests in logical order: foundational facts → event facts → communications → damages → document authentication
3. Include response instructions with deemed-admitted warning
4. Add caption, signature block, and certificate of service

Document Extraction

Before drafting, extract from uploaded documents:

Output Structure

Caption & Header

[COURT NAME]
[CASE TITLE — all parties as captioned]
Case No. [DOCKET NUMBER]
[Judge / Track designation if required]

[REQUESTING PARTY]'S REQUEST FOR ADMISSIONS TO [RESPONDING PARTY]
Set No. [X]

Introduction

• Identify parties by full legal name
• Cite governing rule (FRCP 36 or state equivalent with section number)
• State purpose: narrow issues, establish facts, authenticate documents

Definitions

Include only when specialized terms appear repeatedly. Skip for straightforward cases.

Numbered Requests

Organize in logical progression:

Drafting rules:

• One fact per request — never compound
• Frame affirmatively ("Admit that X occurred"), not negatively
• Use exact dates, names, amounts from case documents
• No ultimate legal conclusions ("Admit you were negligent")
• No double negatives or trick phrasing
• Attach documents as labeled exhibits for authentication requests

Bad: "Admit that you received the notice on March 15 and failed to respond within thirty days." Good: Two separate requests — one for receipt, one for response timing.

Response Instructions

Include all of:

• Response options: admit, deny, or state in detail why party cannot truthfully admit or deny
• Deadline: 30 days after service (FRCP 36(a)(3)) or jurisdiction-specific period
• Deemed-admitted warning: failure to timely respond = matter deemed admitted under [cite rule]
• Reasonable inquiry obligation: lack of knowledge invalid unless reasonable inquiry made
• Supplementation duty: continuing obligation to correct responses
• Objection requirements: must state with specificity; objection does not excuse answering non-objected portions

Signature Block

Dated: _______________

_________________________
[Attorney Name], [Bar No.]
[Firm Name]
[Address]
[Phone] | [Fax]
[Email]
Attorney for [Requesting Party]

Certificate of Service

• Date and method of service (ECF, email, mail, personal delivery)
• Each party/counsel served with address or email
• Signature of certifying attorney

Pitfalls & Checks

• One fact per request — compound requests invite partial denials
• No legal conclusions — "Admit you were negligent" is improper; stick to factual predicates
• Number limits — check local rules before exceeding 25 RFAs
• Judicial vs. pleading admissions — RFA admissions are binding judicial admissions, stronger than pleading admissions
• Avoid harassing requests — skip matters of public record, opinions, or facts solely within requesting party's knowledge
• Verify exhibits — all referenced exhibits must be properly labeled and attached
• Verify rule citations — confirm all citations are current for the specific jurisdiction [VERIFY]
• Tone — neutral, professional, firm; never argumentative

Key changes made:

• Removed tags from frontmatter — not part of the Agent Skills spec (only name and description are valid)
• Trimmed description — tightened wording while preserving all trigger keywords
• Added Quick Start section — gives the agent a fast 4-step overview before diving into details
• Consolidated Prerequisites — collapsed from numbered list to bullet list, merged formatting rules into local rules bullet
• Flattened Output Structure headings — removed redundant numbering (### 1. Caption → ### Caption & Header)
• Consolidated Guidelines into Pitfalls & Checks — merged scattered guidance into a single scannable checklist at the end
• Removed prose padding — cut "Include all of the following", "Organize in logical progression" intros, and other filler phrases
• Reduced line count — from 124 lines to ~105 while preserving all substantive legal content