Request for Admissions Template for Personal Injury Cases
Get Your Request for Admissions Template for Personal Injury Cases
This page covers both, and the downloadable sample shows a real set of requests answered with the plaintiff’s responses.
What Are Requests for Admissions?
Requests for admissions are written statements sent to the opposing party asking them to admit or deny specific facts. Under FRCP 36, they help both sides agree on what is actually in dispute before trial, and what is not. Once a party admits a fact, it is established.
Request for Admissions Template Format
Every request follows a predictable structure, and missing an element creates avoidable problems.
- Caption and case information. Court name, case number, all parties, and a title such as “Plaintiff’s First Request for Admissions to Defendant.”
- Instructions to the responding party. How and when to respond, referencing the applicable rule (FRCP 36 or the state equivalent) and the deadline, typically 30 days from service.
- Numbered admission requests. Each request is numbered and contains a single fact, which prevents partial answers to compound questions.
- Signature block and certificate of service. The attorney’s signature, bar number, and contact information, plus a certificate confirming when and how the requests were served.
What the Sample Requests for Admission Include
The downloadable sample is a set of the plaintiff’s responses to a defendant’s requests for admission in a motor vehicle case, spanning 20 requests, each with the plaintiff’s response. It applies to Florida practice, so treat the rule references as jurisdiction-specific.
Requests for Admissions Examples by Case Type
| Case type | Key admission topics | Unique considerations |
| Motor vehicle | Traffic law compliance, vehicle operation, and road conditions | Police reports, witness statements |
| Premises liability | Property ownership, hazard knowledge, and maintenance duties | Inspection logs, prior incident reports |
| Slip and fall | Notice of condition, warning signage, and floor conditions | Surveillance footage, cleaning schedules |
| Medical malpractice | Provider-patient relationship, standard of care, causation | Medical records, expert testimony |
How to Respond to Requests for Admissions
When your client receives requests for admissions, there are four responses and one hard deadline that overrides them all.
| Response | What it means | Watch out for |
| Admit | The fact is conclusively established | It cannot be contested at trial |
| Deny | You assert the fact is untrue | Requires a good-faith basis; frivolous denials risk sanctions |
| Object | You challenge the request itself | Reserved for vague, compound, or legal-conclusion requests |
| Insufficient information | You cannot truthfully admit or deny after a reasonable inquiry | Must actually make that inquiry first |
How to Draft Effective Requests for Admissions
Good requests get useful admissions while minimizing objections. Each request should target a specific fact that is likely to be admitted by the respondent.
How EvenUp Helps Plaintiff Firms with Discovery
EvenUp’s Request for Admission templates are optimized to secure key admissions that narrow disputes and strengthen settlement leverage. Learn more about EvenUp’s AI Drafts suite.
Frequently Asked Questions
What happens if a party fails to respond to requests for admissions within the deadline?
Unanswered requests are automatically deemed admitted under FRCP 36(a)(3). Deemed admissions are binding and can be used against the non-responding party at trial or in support of summary judgment.
How does a plaintiff respond to a request for admission?
The plaintiff admits, denies, objects, or states that it cannot admit or deny after a reasonable inquiry before the deadline.
When is the best time to serve requests for admissions?
Many attorneys serve them after initial document discovery and depositions provide enough information to craft targeted requests. Serving basic requests early can still establish foundational facts and streamline discovery.
Can a party amend or withdraw an admission after responding?
Courts may permit withdrawal or amendment under FRCP 36(b) if it serves the presentation of the merits and does not prejudice the requesting party. Dependence on this ability is risky.
How many requests for admissions can be served in a personal injury case?
Federal courts generally allow unlimited requests, while many state courts impose numerical limits on requests.