Volume II, Chapter §6.8b
Litigation Documents

Discovery: Request for Admissions

§6.8b
		Introduction
		Commonly Asked Questions
		Demonstration
		Lecture Notes
		Exercise
		Discussion Point Answers

Introduction

Requests for Admissions are powerful tools that force the other party to specifically admit or deny statements.

Requests for Admissions, if used properly and effectively, can be the most powerful tool of discovery other than depositions.

A paralegal can be particular helpful in reminding the attorney of due dates for discovery, especially Requests for Admissions. For this discovery tool, failure to respond to a set of requests, or even a single request, may result in a potentially damaging scenario: The request may be deemed to be admitted by the requesting party.

Thus, responding fully, and on time, to Requests for Admissions is particularly important.

Commonly Asked Questions . . .*

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Demonstration

Discovery Documents

Lecture Notes . . .

The Power of Requests for Admissions
Consider the various forms of discovery.

Interrogatories are questions that the other party responds to. Attorneys (helping their client respond) are experts at avoiding direct answers.

Requests for Production ask the other party to turn over relevant physical information. Of course, these can be very helpful, but it is up to the requesting party to determine the relevance of documents that are produced.

Requests for Mental or Physical Examination will help determine whether there is a basis for an alleged claim, such as emotional distress or a physical injury. But if mental or physical issues aren't relevant to the litigation, these will not be requested.

By contrast, with Requests for Admissions a party can literally say, "Admit or deny that you committed this act," and the other party must respond. If a request is well phrased, it is very difficult for a responding party to talk their way around a statement. The manual presents effective techniques and strategies for creating requests.

Exercise

Requests for Admissions

The Good, the Bad, and the Ugly Time Sheets
Click on the examples of Time Sheets below to zoom in and compare. Yours should look like the Good example.


The Good	The Bad	The Ugly

Time Sheet Download
Click here to download a Time Sheet that automatically adds up your billable hours. You should keep track of any research or writing you do on behalf of your client, including the written assignments in this chapter.