- 1). Review the request for admissions and any attachments you received. The opposing party may have included instructions explaining what the request is and how you should respond. If so, read these instructions carefully and refer to them often as you complete the request. Otherwise, you may receive a second request asking you to repeat the process again.
- 2). Locate and organize any documents or other evidence in your personal records that are pertinent to the matter. You may use documents, including police reports, insurance policies, contracts and general correspondence, to assist you in your response unless the instructions you received explicitly state otherwise.
- 3). Review the statements within the request for admissions. Make a note of any statement that you believe is erroneous, incomplete or for which you are unsure of the answer. As you do this, also make a note of any statement for which you may need to refer to other documents or evidence to confirm your admission.
- 4). Draft your initial answers to each statement on a scratch piece of paper. There are four ways to answer each statement: "admit," "deny," "partially admit/partially deny" and "unknown/unsure at this time." You must provide a reason for any response other than "admit." You may also object to any statements that speculate or call for privileged information, although requests for admissions rarely contain the latter.
- 5). Compare your initial responses to the documents and other evidence you previously compiled. Ensure that your responses are accurate and complete. Remember, any admissions you make become fact at trial, and your responses become a permanent part of the court's record, so it is imperative that your answers are correct and inclusive.
- 6). Prepare a new typewritten document. Type your responses to the request for admissions using your initial draft as a guide. For statements that you partially or wholly deny, point to any documents you have that corroborate your assertion using the exhibit method; i.e., "Refer to "Exhibit A," et cetera.
- 7). Review your typewritten responses once more. Compare your responses to the statements to check for accuracy. Do not allow anyone else to review your answers for you, even if they are a party to the matter; your responses must be yours and yours alone.
- 8). Print your typewritten responses and sign the bottom of the document. Make a copy of your responses, the original request for admissions and any documents you referred to as exhibits within your responses.
- 9). Submit your responses to the opposing party by mail. Include copies (not originals!) of your exhibits, but do not include your draft or any other documents, as these are privileged and the opposing party is not privy to this information. Use Certified Mail with return receipt or a courier to return your responses; do not use regular mail. Retain the receipt for your personal records as proof that you responded to the request for admissions.
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