Request For Admissions

---
name: request-for-admissions
description: Drafts Requests for Admissions under FRCP 36 or state equivalents for personal injury litigation. Extracts facts from case documents to produce numbered admission requests covering factual matters, document authentication, and law-to-fact application. Use when drafting RFAs, narrowing trial issues, authenticating exhibits, or preparing discovery requests.
---

# 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