Numbered Answers
Address each request in order and label with the propounding party’s request number for traceability and clarity.
A precise response limits issues, prevents inadvertent admissions, and preserves objections and evidentiary rights under FRCP 36 or state equivalents.
The parties most directly involved in drafting and serving RFA responses are litigation counsel and the client, supported by litigation support or in-house legal teams.
In many matters, paralegals and eDiscovery teams assemble the factual record while attorneys craft legal objections and verify factual statements.
An attorney of record usually signs the response and certifies its contents under applicable procedural rules; they must ensure factual assertions are supported by client records or a stated lack of knowledge following reasonable inquiry.
When a response depends on corporate facts, a named corporate representative or officer may verify the answers under oath, attesting that the company made a reasonable inquiry and the answers are true to the best of their knowledge.
| Field | Configuration |
|---|---|
| Document Upload | PDF or DOCX; central case folder |
| Template | Pre-built answer template with numbered fields |
| Signer Roles | Attorney, client representative |
| Audit Trail | Capture timestamps, IPs, and access logs |
Ensure the platform supports secure signing, audit trails, and integration with your case management tools before use.
Typically 30 days after service under FRCP 36 unless a different period is prescribed.
Many states follow similar timeframes; consult local rules for exact timing and extensions.
Parties may stipulate longer deadlines; document any agreement in writing.
If responses are inadequate, the propounding party may move for an order compelling answers.
Late or absent answers risk being deemed admissions or generating sanctions.
Opposing party serves numbered admission requests to the respondent.
Respondent must serve answers by the applicable deadline, commonly 30 days.
If answers are deficient, propounding party may move to compel or to have matters admitted.
Court may issue orders requiring supplementation, sanctions, or deeming admissions.
A corporate defendant received 50 RFAs and admitted 6 immaterial facts
A plaintiff propounded RFAs to establish a timeline of events
Address each request in order and label with the propounding party’s request number for traceability and clarity.
Explicitly state admitted facts and, where appropriate, cite produced documents or deposition pages as support.
Deny with a concise factual basis and reference to any documents contradicting the allegation.
Partially admit specific points while denying others, stating the scope of the admission precisely.
State specific objections (overbroad, vague, privileged) and whether any portion is answered subject to the objection.
Include a signed certificate showing how and when the response was served to meet procedural rules.
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|---|---|---|---|---|---|
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