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Requests for Admission: Achieving What Other Discovery Cannot, Reducing Costs, Supporting Summary Judgment

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, January 30, 2024

Recorded event now available

or call 1-800-926-7926

This CLE webinar will guide seasoned trial attorneys on the most effective use of requests for admission (RFAs) and the best response strategies. The panel will cover the underappreciated value of RFAs, their purposes, the proper scope of RFAs, how to respond and object adequately, and strategies to employ when the opposing party fails to respond.


Underutilized and underappreciated, RFAs can accomplish things that other forms of discovery cannot. RFAs can effectively confirm essential facts in the case and alleviate the need for more expensive discovery.

RFAs are powerful in part because they are generally not limited to matters within the personal knowledge of the responding party, and the responding party must make a reasonable investigation before claiming a lack of information. In answering an RFA with a lack of knowledge response, the party should be prepared to testify as to why such an answer was provided at deposition.

Any matter deemed admitted is conclusively established, with narrow exceptions. For maximum effect, RFAs should be clearly and carefully drafted in light of the elements of the claims and defenses. RFAs should be appropriately timed and part of an overall discovery plan driving toward summary judgment or trial. Recycled RFAs or those that incorporate overbroad definitions can be self-defeating.

Listen as this distinguished panel guides counsel through how RFAs can make a big difference in the case, including reducing costs and laying the foundation for summary judgment.



  1. Overview of FRCP 36 and state counterparts
  2. Timing, planning, and drafting productive RFAs
  3. Responding to RFAs and contending with evasive answers
  4. Enforcement and strategic use of RFAs
  5. Altering or amending responses to the admissions


The panel will discuss these and other pivotal issues:

  • Which issues are best suited for RFAs?
  • How can counsel avoid unclear RFAs?
  • What is an acceptable explanation for "lack of sufficient information" to admit or deny?
  • Can facts incorrectly, but in good faith, admitted, be corrected?


Cooper, Miles
Miles B. Cooper


Compassion combined with trial experience, strategy, risk assessment, passionate communication, growth, relentless...  |  Read More

Flora, Colin
Colin E. Flora

Civil Litigation Attorney
Pavlack Law

Mr. Flora focuses his practice on civil litigation for both plaintiffs and defendants. This ranges from personal injury...  |  Read More

Frankenstein, Sara
Sara Frankenstein

Gunderson, Palmer, Nelson & Ashmore

Ms. Frankenstein is a partner of Gunderson, Palmer, Nelson & Ashmore, LLP. She practices in the areas of Employment...  |  Read More

Roth, Robert
Robert A. Roth

Complex Appellate Litigation Group

Mr. Roth is widely regarded as one of the leading family law appellate specialists in California. He has over 30...  |  Read More

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