Request for Admissions – Standard Requests
REQUESTS FOR ADMISSIONS
Admit or deny the truth of the following statements:
{CHOOSE APPROPRIATE REQUESTS}
REQUEST 1: Plaintiff {properly/improperly} named defendant in plaintiff’s original petition.
REQUEST 2: The document attached as Exhibit {letter} is a genuine copy of that document.
REQUEST 3: The document attached as Exhibit {letter} was received by {adverse party} {on/after/before} {date}.
REQUEST 4: The document attached as Exhibit {letter} was created {on/after/before} {date}.
REQUEST 5: The document attached as Exhibit {letter} was signed {on/after/before} {date}.
REQUEST 6: The {signature/initials} on page {number} of the document attached as Exhibit {letter} {was/were} made by {adverse party/{name of adverse party’s employee}}.
REQUEST 7: The original of the document attached as Exhibit {letter} is in the possession, custody, or control of {adverse party}. {Ask for production of original in request for production here or in a separate document.}
REQUEST 8: {Adverse party/{name of adverse party’s employee}} learned {on/before} {date}, that {state facts that would trigger limitations}.
REQUEST 9: {Adverse party/{name of adverse party’s employee}} was convicted of a felony or a crime involving moral turpitude. {Ask for more information in an interrogatory here or in a separate document.}
REQUEST 10: The judgment attached as Exhibit {letter} is a correct copy of the judgment of conviction rendered against {adverse party/{name of adverse party’s employee}} by the court {after a jury trial/upon a plea of guilty}.
REQUEST 11: {Adverse party} received proper presuit notice of {party}’s claim, as required by {identify contract, statute, or rule that required presuit notice}. {Ask for more information in an interrogatory here or in a separate document.}
REQUEST 12: {Name of adverse party’s employee} was acting in the course and scope of {his/her} employment when {he/she} {describe conduct}.
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