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Requests for Admission 2- Model for Car Accident Case

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Plaintiff, [name of plaintiff], serves this First Request for Admissions on you, the Defendant in the above-entitled action, pursuant to [citation of court rule]. You must answer each separately, fully, in writing, and under oath, within [number of days] days after service.


1. For each document or other information that you assert is privileged or for any other reason excludable from discovery, please identify that document or other requested information. State the specific grounds for the claim of privilege or other ground for exclusion. Also, for each document, state the date of the document, the name, job title, and address of the person who prepared it; the name, address, and job title of the person to whom it was addressed or circulated or who saw it; the name, job title, and address of the person now in possession of the document; and a description of the subject matter of the document.

2. For any requested information about a document that no longer exists or cannot be located, identify the document, state how and when it passed out of disappearance. Also, identify each person having knowledge about the disposition or loss and identify each document evidencing the existence or nonexistence of each document that cannot be located.


The following definitions shall have the following meanings, unless the context requires otherwise:

1. “Plaintiff” or “[name of plaintiff]” means Plaintiff, and/or Plaintiff's agents, representatives, and all other persons acting in concert with, or under control, whether directly or indirectly, excluding Plaintiff's attorney.

2. “Defendant” or “[name of defendant]” means Defendant, and/or Defendant's agents, representatives, and all other persons acting in concert with, or under control, whether directly or indirectly, excluding Defendant's attorney.

3. “You” or “your” means Defendant, [name of defendant], and/or Defendant's successors, predecessors, divisions, subsidiaries, present and former officers, agents, employees, and all other persons acting on behalf of Defendant, successors, predecessors, divisions, and subsidiaries.

4. “Document(s)” means all written, typed, or printed matter and all magnetic or other records or documentation of any kind or description (including, without limitation, letters, correspondence, telegrams, memoranda, notes, records, minutes, contracts, agreements, records, or notations of telephone or personal conversations, conferences, inter-office communications, E-mail, microfilm, bulletins, circulars, pamphlets, photographs, facsimiles, invoices, tape recordings, computer printouts and work sheets), including drafts and copies not identical to the originals, all photographs and graphic matter, however produced or reproduced, and all compilations of data from which information can be obtained, and any and all writings or recordings of any type or nature, in your actual possession, custody, or control, including those in the possession, custody, or control of any and all present or former directors, officers, employees, consultants, accountants, attorneys, or other agents, whether or not prepared by you.

5. “File” means any collection or group of documents maintained, held, stored, or used together, including, without limitation, all collections of documents maintained, held, or stored in folders, notebooks, or other devices for separating or organizing documents.

6. “Person” means any natural person, corporation, firm, association, partnership, joint venture, proprietorship, governmental body, or any other organization, business, or legal entity, and all predecessors or successors in interest.

7. “Relating to” and “relates to” mean, without limitation, embodying, mentioning, or concerning, directly or indirectly, the subject matter identified in the request.

8. “Concerning” means, in whole or in part, directly or indirectly, referring to, relating to, connected with, commenting on, responding to, showing, describing, analyzing, reflecting, and constituting.

9. “Communication” means any oral or written communication of which the Defendant has knowledge, information, or belief.

10. “Date” means the exact date, month, and year, if ascertainable, or, if not, the best available approximation.

11. “Describe” or “identify,” when referring to a document, means you must state the following:

(a) The nature (e.g., letter, handwritten note) of the document;

(b) The title or heading that appears on the document;

(c) The date of the document and the date of each addendum, supplement, or other addition or change;

(d) The identity of the author and of the signer of the document, and of the person on whose behalf or at whose request or direction the document was prepared or delivered;

(e) The present location of the document, and the name, address, position or title, and telephone number of the person or persons having custody of the document.

12. The word “and” means “and/or.”

13. The word “or” means “or/and.”

14. “Accident,” “incident,” or “collision,” refers to the incident pleaded in Plaintiff's petition(s).



Please admit that Plaintiff's medical care and bills, as claimed are related to the injuries suffered in the accident that is the basis for this lawsuit, were reasonable and necessary.


Please admit that Defendant was involved in a collision on [date of accident].


Please admit that Plaintiff suffered injuries as the proximate result of a collision that occurred on [date of accident].


Please admit that Plaintiff suffered injuries proximately caused by your negligence.


Please admit that Defendant is liable to Plaintiff for the injuries suffered on [date of accident].


Please admit that at the time of the incident Plaintiff lost wages in the past as a proximate result of your negligence.


Please admit that Plaintiff was injured as a proximate result of the incident made the basis of this lawsuit.


Please admit that Defendant is vicariously liable for all acts and/or omissions of negligence on the part of its driver at the time of the incident made the basis of this lawsuit.


Please admit that as a proximate result of the negligent acts and/or omissions of the Defendant, Plaintiff has suffered painful personal injuries.


Please admit that Plaintiff has endured physical and mental pain and suffering in the past as a proximate result of the incident made the basis of this lawsuit.

Dated: [date of request]

[Name of attorney for plaintiff]

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