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:

| Extract | Examples |
|---|---|
| Party names & roles | Full legal names as captioned |
| Key dates & timeline | Incident, notice, treatment dates |
| Monetary amounts | Medical bills, lost wages, demands |
| Documents to authenticate | Contracts, letters, emails, records |
| Admitted allegations | Facts already admitted in answer |
| Communications | Emails, texts, letters with dates and participants |

## 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:

| Category | Order | Example |
|---|---|---|
| Foundational facts | First | Relationships, residence, employment, contract existence |
| Event-specific facts | Second | Incident details, dates, locations, actions |
| Communications | Third | Sending/receipt of documents on specific dates |
| Damages | Fourth | Treatment, amounts billed, payment responsibility |
| Document authentication | Last | Genuineness of attached exhibits |

**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