Sample Request for Admissions

 

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        Our lawyers have long maintained that filing requests for admission in every case is essential even if all you accomplish is establishing obvious elements of your burden of proof. Another good use of requests for admission is to follow up critical denials with alternative interrogatories, drafted in light of the defendant's lawyers answers to requests for admission. This is an easy way to flush out form denials. One of our lawyers, learned this tactic during another life as a defense lawyer, remembering well trying to avoid the "rubber meets the road" of having to give legitmate answers. So, being a defense lawyer, he denied most of the requests and provided no real information and make not strategic committments. . The plaintiff's lawyer, a product liability lawyer in Indiana, followed up with good alternative interrogatories that went to all of the issues the defendant was trying to avoid taking a clear cut position on at that stage of the case. They were just really tough questions to answer. The lesson was learned: our lawyers file requests for admission in virtually every personal injury case.

        Requests for admission often do not receive honest answers with "Deny Deny Deny" lawyers. "Plaintiff was injured in the accident" is a good example. If this request is denied, a good accident or malpractice lawyer will read the answers to a jury which is consistent with a common theme personal injury lawyers use in many cases: the defendant is refusing to accept any responsibility, even for painfully obvious facts that anyone reasonable would concede.

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