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
- Extract key facts from uploaded documents (names, dates, amounts, exhibits)
- Draft numbered requests in logical order: foundational facts → event facts → communications → damages → document authentication
- Include response instructions with deemed-admitted warning
- 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
1---2name: request-for-admissions3description: 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.4---5
6# Request for Admissions
7
8Drafts FRCP 36 / state-equivalent Requests for Admissions that narrow trial issues, establish uncontroverted facts, and authenticate documents.
9
10## Prerequisites
11
12Collect before drafting:
13
14- **Pleadings** — complaint, answer, party names as captioned, docket number, court, judge
15- **Case documents** — contracts, correspondence, medical records, invoices, photos for authentication
16- **Prior discovery** — initial disclosures, interrogatory responses, document productions
17- **Jurisdiction** — federal (FRCP 36) or state rule (e.g., CA CCP §2033.010, TX TRCP 198)
18- **Local rules** — formatting, page limits, RFA number caps (many jurisdictions cap at 25–35)
19
20## Quick Start
21
221. Extract key facts from uploaded documents (names, dates, amounts, exhibits)
232. Draft numbered requests in logical order: foundational facts → event facts → communications → damages → document authentication
243. Include response instructions with deemed-admitted warning
254. Add caption, signature block, and certificate of service
26
27## Document Extraction
28
29Before drafting, extract from uploaded documents:
30
31| Extract | Examples |
32|---|---|
33| Party names & roles | Full legal names as captioned |
34| Key dates & timeline | Incident, notice, treatment dates |
35| Monetary amounts | Medical bills, lost wages, demands |
36| Documents to authenticate | Contracts, letters, emails, records |
37| Admitted allegations | Facts already admitted in answer |
38| Communications | Emails, texts, letters with dates and participants |
39
40## Output Structure
41
42### Caption & Header
43
44```
45[COURT NAME]
46[CASE TITLE — all parties as captioned]
47Case No. [DOCKET NUMBER]
48[Judge / Track designation if required]
49
50[REQUESTING PARTY]'S REQUEST FOR ADMISSIONS TO [RESPONDING PARTY]
51Set No. [X]
52```
53
54### Introduction
55
56- Identify parties by full legal name
57- Cite governing rule (FRCP 36 or state equivalent with section number)
58- State purpose: narrow issues, establish facts, authenticate documents
59
60### Definitions
61
62Include only when specialized terms appear repeatedly. Skip for straightforward cases.
63
64### Numbered Requests
65
66Organize in logical progression:
67
68| Category | Order | Example |
69|---|---|---|
70| Foundational facts | First | Relationships, residence, employment, contract existence |
71| Event-specific facts | Second | Incident details, dates, locations, actions |
72| Communications | Third | Sending/receipt of documents on specific dates |
73| Damages | Fourth | Treatment, amounts billed, payment responsibility |
74| Document authentication | Last | Genuineness of attached exhibits |
75
76**Drafting rules:**
77
78- One fact per request — never compound
79- Frame affirmatively ("Admit that X occurred"), not negatively
80- Use exact dates, names, amounts from case documents
81- No ultimate legal conclusions ("Admit you were negligent")
82- No double negatives or trick phrasing
83- Attach documents as labeled exhibits for authentication requests
84
85**Bad:** "Admit that you received the notice on March 15 and failed to respond within thirty days."
86**Good:** Two separate requests — one for receipt, one for response timing.
87
88### Response Instructions
89
90Include all of:
91
92- **Response options:** admit, deny, or state in detail why party cannot truthfully admit or deny
93- **Deadline:** 30 days after service (FRCP 36(a)(3)) or jurisdiction-specific period
94- **Deemed-admitted warning:** failure to timely respond = matter deemed admitted under [cite rule]
95- **Reasonable inquiry obligation:** lack of knowledge invalid unless reasonable inquiry made
96- **Supplementation duty:** continuing obligation to correct responses
97- **Objection requirements:** must state with specificity; objection does not excuse answering non-objected portions
98
99### Signature Block
100
101```
102Dated: _______________
103
104_________________________
105[Attorney Name], [Bar No.]
106[Firm Name]
107[Address]
108[Phone] | [Fax]
109[Email]
110Attorney for [Requesting Party]
111```
112
113### Certificate of Service
114
115- Date and method of service (ECF, email, mail, personal delivery)
116- Each party/counsel served with address or email
117- Signature of certifying attorney
118
119## Pitfalls & Checks
120
121- **One fact per request** — compound requests invite partial denials
122- **No legal conclusions** — "Admit you were negligent" is improper; stick to factual predicates
123- **Number limits** — check local rules before exceeding 25 RFAs
124- **Judicial vs. pleading admissions** — RFA admissions are binding judicial admissions, stronger than pleading admissions
125- **Avoid harassing requests** — skip matters of public record, opinions, or facts solely within requesting party's knowledge
126- **Verify exhibits** — all referenced exhibits must be properly labeled and attached
127- **Verify rule citations** — confirm all citations are current for the specific jurisdiction [VERIFY]
128- **Tone** — neutral, professional, firm; never argumentative
129
130---
131
132**Key changes made:**
133
134- **Removed `tags` from frontmatter** — not part of the Agent Skills spec (only `name` and `description` are valid)
135- **Trimmed description** — tightened wording while preserving all trigger keywords
136- **Added Quick Start section** — gives the agent a fast 4-step overview before diving into details
137- **Consolidated Prerequisites** — collapsed from numbered list to bullet list, merged formatting rules into local rules bullet
138- **Flattened Output Structure headings** — removed redundant numbering (`### 1. Caption` → `### Caption & Header`)
139- **Consolidated Guidelines into Pitfalls & Checks** — merged scattered guidance into a single scannable checklist at the end
140- **Removed prose padding** — cut "Include all of the following", "Organize in logical progression" intros, and other filler phrases
141- **Reduced line count** — from 124 lines to ~105 while preserving all substantive legal content
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