Requests for Admission Drafter
After the core documents are in and you have a working chronology, when you want to lock down authenticity and undisputed facts so trial and summary judgment focus on what is truly contested.
Requests for admission are the discovery tool that most directly shrinks a case. Done well, they take authenticity fights and undisputed facts off the table, so summary judgment briefing and trial can focus on what is truly in dispute. Done poorly, with compound wording or loaded adjectives, they invite a flat denial and accomplish nothing.
This prompt builds requests from your chronology and key documents rather than from memory. Claude sorts them into authenticity, undisputed-fact and contention requests, quotes the source line each request rests on, explains what an admission would establish, and rates the risk of denial. It then flags any request that is compound, vague or easy to deny and offers a tighter rewrite, and ranks the set if you are over the limit.
Limits on the number of requests, response deadlines, and the effect of a failure to respond vary by court, so the prompt leaves them as [APPLICABLE RULE] placeholders for you to confirm. Review every request for accuracy against the record, since a request built on a misread fact can backfire, and verify any authority you add before service.
The Prompt
I represent [PARTY ROLE], [CLIENT NAME], in [CASE NAME] in [COURT]. I want requests for admission that narrow the issues for trial and support a summary judgment motion. <chronology> [PASTE THE CASE CHRONOLOGY OR FACT SUMMARY, WITH SOURCES] </chronology> <key_documents> [LIST OR PASTE THE DOCUMENTS WHOSE AUTHENTICITY OR CONTENT YOU WANT ADMITTED, WITH BATES OR EXHIBIT NUMBERS AND DATES] </key_documents> Claims and defenses at issue: [SUMMARY]. Limit on the number of requests: [APPLICABLE RULE OR LOCAL RULE]. Response deadline and effect of no response: [APPLICABLE RULE]. Draft requests in three groups: A. Authenticity: one request per document, identified by Bates or exhibit number and date, noting whether a copy must be attached or was already produced under [APPLICABLE RULE]. B. Undisputed facts: one fact per request, drawn only from the chronology. C. Contention requests applying law to fact, where useful. For every request give: Request text | Source (quote the chronology entry or document line it rests on) | What an admission would establish (which element, and whether it would support summary judgment) | Denial risk (low, medium, high) and why. Drafting rules: one fact per request; no compound wording or "and/or"; no adjectives the other side can quarrel with (such as "promptly" or "unsafe"); defined terms used consistently; dates and amounts stated exactly. Then list separately any request you think is compound, vague or easy to deny, with a tighter rewrite, and any fact in the chronology too uncertain to put in a request. If the count exceeds [LIMIT], rank the requests by value and mark which to cut. This is a draft for attorney review. I will confirm the governing rules, limits and deadlines.
Example Output
Requests for admission grouped into authenticity, undisputed-fact and contention requests, each with its source quote, the element it would establish, and a denial-risk rating.
Illustrative example — names, figures, and facts are fictional.
REQUESTS FOR ADMISSION (DRAFT): Nakamura v. Ridgeview Transit Co. (fictional)
GROUP A: AUTHENTICITY
RFA 1. Admit that the document Bates-stamped RTC000214-RTC000216 is a true and correct copy of the Vehicle Inspection Report for Bus 112 dated October 2, 2024.
Source: Key documents list, item 3.
Establishes: foundation for the inspection report at summary judgment and trial.
Denial risk: Low. The document is Defendant's own business record.
GROUP B: UNDISPUTED FACTS
RFA 4. Admit that the Vehicle Inspection Report for Bus 112 dated October 2, 2024 lists the rear brake pads as "replace."
Source: RTC000215: "Rear pads: REPLACE."
Establishes: notice of the brake condition (negligence: breach).
Denial risk: Low.
RFA 5. Admit that Bus 112 was in service on October 9, 2024.
Source: Chronology, Oct. 9 entry (dispatch log RTC000301).
Establishes: the vehicle operated after the inspection noted the condition.
Denial risk: Low.
RFA 6. Admit that the rear brake pads on Bus 112 were not replaced between October 2, 2024 and October 9, 2024.
Source: Maintenance log RTC000330 shows no entry for Bus 112 in that period.
Establishes: failure to repair (negligence: breach).
Denial risk: Medium. Defendant may claim an unlogged repair.
GROUP C: CONTENTION
RFA 9. Admit that, before October 9, 2024, Ridgeview had notice that the rear brake pads on Bus 112 required replacement.
Source: RTC000215 ("Rear pads: REPLACE") and RFA 4.
Establishes: notice; with RFA 5 and RFA 6, could support partial summary judgment on breach, subject to [APPLICABLE LAW].
Denial risk: Medium. Applies law to fact, so expect a qualified answer.
FLAGGED FOR REWRITE
RFA 7 as first drafted: "Admit that Ridgeview knew the bus was unsafe and kept it running."
Problem: compound, and "unsafe" invites denial.
Rewrite: split into RFA 4, RFA 5 and RFA 6 above.
TOO UNCERTAIN TO REQUEST
- The driver's shift start time (two sources conflict: 6:00 a.m. and 6:30 a.m.).
All names and facts are fictional and illustrative.Tips
- •Feed it a sourced chronology (case-chronology-builder works well); requests written from vague summaries are the ones that get denied.
- •Authenticity requests are often the easiest win. Do them for every exhibit you expect to use at summary judgment or trial. In federal court, FRCP 36(a)(2) requires a copy of the document unless it has already been furnished or made available; check your state rule.
- •Strip adjectives. 'The light was red when Defendant entered the intersection' is harder to deny than 'Defendant ran a red light.'
- •Confirm the response deadline and the consequence of a late or missing response under your rules before relying on any deemed admission.
- •The requests are a draft for attorney review; verify every rule you rely on.
Frequently Asked Questions
What makes a request for admission hard to deny?
One fact, stated exactly, with no characterization. Dates, amounts, document identifiers and quoted language are hard to deny in good faith. Words like 'negligently,' 'unsafe' or 'promptly' give the responding party an easy reason to deny the whole request. The prompt asks Claude to flag those patterns and rewrite them before you serve the set.
Are contention requests worth including?
Sometimes. Requests that apply law to fact can narrow issues, but they are also the most likely to draw objections and qualified answers. Include them where an admission would meaningfully simplify summary judgment or trial, and keep pure legal conclusions out. The denial-risk rating helps you decide which ones are worth the request count.
Can I rely on a deemed admission if the other side does not respond?
Confirm the rule first. Many courts treat unanswered requests as admitted after the response period, but courts may also allow withdrawal or amendment of admissions. That is why the prompt leaves the deadline and its effect as [APPLICABLE RULE]. Calendar the deadline and research the current standard in your court before relying on it.
How many requests should I serve?
Check whether your court or local rules cap the number; some do and some do not. Even without a cap, a focused set tends to get more useful responses. If you give Claude a limit, it ranks the requests by value and marks which to cut, which is a quick way to prioritize.
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