Requests for Admission: Achieving What Other Discovery Cannot, Reducing Costs, Supporting Summary Judgment

This CLE webinar will guide seasoned trial attorneys on the most effective use of requests for admission (RFAs) and the best response strategies. The panel will cover the underappreciated value of RFAs, their purposes, the proper scope of RFAs, how to respond and object adequately, and strategies to employ when the opposing party fails to respond.

Underutilized and underappreciated, RFAs can accomplish things that other forms of discovery cannot. RFAs can effectively confirm essential facts in the case and alleviate the need for more expensive discovery.

RFAs are powerful in part because they are generally not limited to matters within the personal knowledge of the responding party, and the responding party must make a reasonable investigation before claiming a lack of information. In answering an RFA with a lack of knowledge response, the party should be prepared to testify as to why such an answer was provided at deposition.

Any matter deemed admitted is conclusively established, with narrow exceptions. For maximum effect, RFAs should be clearly and carefully drafted in light of the elements of the claims and defenses. RFAs should be appropriately timed and part of an overall discovery plan driving toward summary judgment or trial. Recycled RFAs or those that incorporate overbroad definitions can be self-defeating.

Listen as this distinguished panel guides counsel through how RFAs can make a big difference in the case, including reducing costs and laying the foundation for summary judgment.