Requests for Admissions
Like interrogatories, these may be directed only at parties to the litigation. Unlike interrogatories, however, the questions do not allow for narrative answers. Each question is phrased so that it must be answered as “admitted” or “denied.” Requests for admissions are used to delineate which facts are not in issue and may thus be agreed to before trial. A typical question might be, “Admit or deny that you treated plaintiff on 23 October 1985.”
Once an item has been admitted or denied, the court is reticent about allowing the answer to be changed. The party requesting the right to amend a request for admissions has the burden of convincing the court that there is a good reason that the original answer is incorrect. Conversely, the party requesting the admissions must ask simple and unambiguous questions if he or she wants the answers to be effective in court.