What happens if I do not respond?

If you fail to respond within the time set by the rule, the matters alleged may be deemed admitted. A court may permit withdrawal, but courts apply Rule 36(b) standards and consider prejudice and the merits of withdrawal.

Can admissions be withdrawn later?

Yes; courts may allow amendment or withdrawal under Rule 36(b) where it serves justice. Courts weigh the nature of the admission, prejudice to the requesting party, and the reason for late change.

Are objections alone sufficient?

An objection without a timely answer can lead to adverse consequences. Responding parties should lodge timely objections and, where required, provide partial answers or qualified admissions to avoid automatic admissions.

Can e-signatures be used on responses?

Electronic signatures are generally valid under the ESIGN Act (15 U.S.C. ch. 96) and state UETA statutes, provided intent, consent, attribution, and reliable record retention are satisfied.

How to authenticate attached documents?

Attach clear exhibit labels and source metadata; requests can ask the opponent to admit genuineness. Authentication is easier when documents include external identifiers like recorded instrument numbers.

What security records should I keep?

Retain service proofs, audit logs, timestamps, and preserved originals. Maintain these records for the duration of litigation and any applicable post-resolution retention periods.

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Rule 36 Requests for Admission

Rule 36 Requests for Admission

This template is fully customizable. Edit the text, fill out the fields, and send it for signature. Give it a try!

REQUEST FOR ADMISSIONS TO DEFENDANTS

IN THE CIRCUIT COURT OF , MISSISSIPPI

JUDICIAL DISTRICT

VS. NO.

REQUEST FOR ADMISSIONS TO DEFENDANTS

COMES Plaintiff, and files this its Request for Admissions to Defendants, and pursuant to the Mississippi Rules of Civil Procedure. Each Defendant shall respond to each Request and shall admit or deny within thirty (30) days of receipt of same or objection shall be so filed.

REQUEST #1: Please admit that Plaintiff first began to do business with in 20 .

REQUEST #2: Please admit that business was not incorporated until .

REQUEST #3: Please admit that during Plaintiff's business relationship with you that you advised Plaintiff regarding his/her insurance needs.

REQUEST #4: Please admit that Plaintiff relied upon you to acquire insurance for Plaintiff at reasonable rates.

REQUEST #5: Please admit that Plaintiff relied upon you to obtain his/her Worker's Compensation Insurance from the day it first began to do business with you in 20 , until the Worker's Compensation obtained through you was terminated by Plaintiff.

REQUEST #6: Please admit that Plaintiff relied upon you to obtain its Liability Insurance from the day it first began to do business with you in 20 , until the Liability Insurance obtained through your office was terminated by Plaintiff.

REQUEST #7: Please admit that Plaintiff relied upon you to use reasonable efforts to see that Plaintiffs' Worker's Compensation coverage was not cancelled.

REQUEST #8: Please admit that Plaintiff relied upon you to use reasonable efforts to see that Plaintiff's Liability Insurance was not cancelled.

REQUEST #9: Please admit that you obtained Liability Insurance for Plaintiff from through the .

REQUEST #10: Please admit that the Insurance Policy referred to in Request #9, was issued and that the annual premium was $ .

REQUEST #11: Please admit that the deposit premium for the Commercial Union Insurance Policy referred to in Request #10 was paid by Plaintiff to your office.

REQUEST #12: Please admit that the balance of the was paid .

REQUEST #13: Please admit that sent a renewal notice for the through year, to Plaintiff with an annual premium of $ .

REQUEST #14: Please admit that Plaintiff paid the deposit premium to your office on the renewal policy referred to in Request #13.

REQUEST #15: Please admit that the balance of the premium was paid to your office on .

REQUEST #16: Please admit that issued a renewal notice for the , stating an annual premium of $ .

REQUEST #17: Please admit that the premium amount of $ on the renewal notice of referred to in Request #16 was incorrect.

REQUEST #18: Please admit that Plaintiff contacted you to advise of the incorrect premium.

REQUEST #19: Please admit that you agreed to contact to resolve and correct the premium.

REQUEST #20: Please admit that the deposit premium due on renewal of the was paid by you and that you in turn transmitted same to .

REQUEST #21: Please admit that was ready, willing and able to pay a deposit premium on the upon your request for same.

REQUEST #22: Please admit that you did not request a deposit premium on the from Plaintiff until .

REQUEST #23: Please admit that Plaintiff paid $ to you for a deposit premium for the on the same date you invoiced it for same.

REQUEST #24: Please admit that prior to , you had not requested or invoiced Plaintiff for the deposit premium on the Premium policy renewal.

REQUEST #25: Please admit that the reason you had not requested a deposit premium from Plaintiff on the renewal, was because the annual premium had not been resolved with .

REQUEST #26: Please admit that the deposit premium on the should be % of the annual premium.

REQUEST #27: Please admit that had instructed you to disregard the renewal notice which showed the premium to be $ .

REQUEST #28: Please admit that you contend that had not advised you to send the deposit premium on the policy until .

REQUEST #29: Please admit that you contend that you transmitted the deposit premium of $ less commissions to on or about .

REQUEST #30: Please admit that you contend that refused to accept the deposit premium and returned same to you.

REQUEST #31: Please admit that you contend that advised you that the policy would not be cancelled if the deposit premium were mailed on .

REQUEST #32: Please admit that you contend that the accounting and underwriting departments of were not coordinating their efforts regarding the renewal policy.

REQUEST #33: Please admit that the Policy was cancelled by effective .

REQUEST #34: Please admit that refused to accept the deposit premium although it was tendered to them prior to the cancellation date of .

REQUEST #35: Please admit that Mr./Ms. with Underwriting sent you a memorandum dated stating that the annual premium with the Policy was revised from $ to $ and that the deposit premium was $ .

REQUEST #36: Please admit that , in the memo referred to in Request #35, stated that the deposit premium must be received by .

REQUEST #37: Please admit that you did not advise Plaintiff of the memo referred to in Request #35.

REQUEST #38: Please admit that you did not advise Plaintiff of the memo referred to in Request #35, because was revising the annual premium again.

REQUEST #39: Please admit that you contend that you were not advised by of the final revised premium of $ until .

REQUEST #40: Please admit that you did not collect a deposit premium from Plaintiff for the with an annual premium of $ until .

REQUEST #41: Please admit that the deposit premium due on the Liability Policy issued to the assigned risk plan should be % of the annual premium.

REQUEST #42: Please admit that you collected % of $ as a deposit premium on the .

REQUEST #43: Please admit that you contend that advised you to collect $ , although had revised the annual premium to $ .

REQUEST #44: Please admit that your failure to collect and forward the deposit premium to for the constituted negligence.

REQUEST #45: Please admit that you owed Plaintiff a duty to collect and forward the deposit premium to on a timely basis.

REQUEST #46: Please admit that 's cancellation of the policy was improper.

REQUEST #47: Please admit that you are authorized by to accept deposit premiums on its behalf.

REQUEST #48: Please admit that you contend that verbally advised you on , that the deposit premium for the policy was received late.

REQUEST #49: Please admit that you reapplied to the on .

REQUEST #50: Please admit that the assigned risk plan rules and regulations require that Plaintiffs' coverage be replaced with , the carrier which had cancelled coverage.

REQUEST #51: Please admit that Plaintiffs' coverage was not reassigned to but to the .

REQUEST #52: Please admit that the reason Plaintiffs' coverage was not assigned to was because of your failure to advise the assigned risk plan that coverage had previously been with .

REQUEST #53: Please admit that the reason Plaintiffs' coverage was not reassigned to was because refused to accept reassignment.

REQUEST #54: Please admit that the final rate of the Policy was approximately $ higher than the rate.

REQUEST #55: Please admit that Plaintiff cancelled the Policy on .

REQUEST #56: Please admit that Plaintiff was due a return premium upon cancellation of the Policy.

REQUEST #57: Please admit that did not issue a return premium to Plaintiff until .

REQUEST #58: Please admit that the assigned risk plan requires premium returns to be made within thirty (30) days of cancellation. Please admit that thirty (30) days was a reasonable amount of time for to calculate the return of premium.

REQUEST #59: Please admit that failed to return the unearned premium within a reasonable time.

REQUEST #60: Please admit that deducted from the return premium to Plaintiff unearned commissions.

REQUEST #61: Please admit that insurance industry practice is to make return premiums to the insured without deducting unearned commissions.

REQUEST #62: Please admit that you were paid by unearned commissions totaling approximately $ .

REQUEST #63: Please admit that you owe unearned commissions to Plaintiff or to .

REQUEST #64: Please admit that withholding unearned commissions paid to you from the unearned premium payment to Plaintiff was improper.

REQUEST #65: Please admit that you advised that it was improper for them to withhold unearned commissions from the payment to Plaintiff.

REQUEST #66: Please admit that refused to take action on your advice.

REQUEST #67: Please admit that you received for Plaintiff a policy of insurance from , # in .

REQUEST #68: Please admit that the premium for this coverage was paid through your office.

REQUEST #69: Please admit that Plaintiff overpaid you for this coverage.

REQUEST #70: Please admit that the amount of overpayment was approximately $ .

REQUEST #71: Please admit that you forwarded the premium on this policy to , including the overpayment.

REQUEST #72: Please admit that you were an agent of at the time you collected the excess premium from Plaintiff.

REQUEST #73: Please admit that has returned the excess premium to you.

REQUEST #74: Please admit that has returned a portion of the excess premium to you.

REQUEST #75: Please admit that you owe Plaintiff the excess premium charged on the ' policy.

REQUEST #76: Please admit that cancelled Plaintiffs' Workers Compensation coverage effective .

REQUEST #77: Please admit that cancelled Plaintiffs' Workers Compensation coverage based upon premium payments it alleged were passed due.

REQUEST #78: Please admit that sent correspondence to Plaintiff dated , advising Plaintiff that certain premium payments had not been paid.

REQUEST #79: Please admit that Plaintiff contacted you to contact about the premium payments.

REQUEST #80: Please admit that you requested an explanation from in the form of an accounting concerning premiums due.

REQUEST #81: Please admit that did not provide you with an accounting as requested.

REQUEST #82: Please admit that did not respond to the request for an accounting.

REQUEST #83: Please admit that despite your request for an accounting cancelled the Workers Compensation coverage effective .

REQUEST #84: Please admit that had ample time to provide Plaintiff with an accounting prior to the cancellation of .

REQUEST #85: Please admit that you did not advise Plaintiff that the disputed premiums alleged were unpaid had to be paid in order to avoid cancellation.

REQUEST #86: Please admit that Plaintiff had actually paid the premium in the amount of $ to , which alleged was unpaid, and showed its cancelled check to you.

REQUEST #87: Please admit that you advised that the alleged premium due in the amount of $ had been paid and provided them with the cancelled check.

REQUEST #88: Please admit that did not respond or reply after you provided it with the cancelled check referred to in Request #87.

REQUEST #89: Please admit that maintains a formal policy of not advising insureds names of people to contact about questions concerning an insured's policy, premium notices, cancellation notices and the like.

REQUEST #90: Please admit that makes it difficult for insureds to determine how to contact it regarding the insured's policy written by .

REQUEST #91: Please admit that does not provide insureds with telephone numbers to call if the insured has questions about a premium statement, notice of cancellation or other like information.

REQUEST #92: Please admit that during the period of time wrote insurance for Plaintiff, did not advise you of the names of people or their location, address or telephone number to contact regarding questions about policies it had issued.

REQUEST #93: Please admit that relies upon its agents to resolve or answer questions which an insured may have regarding a policy.

REQUEST #94: Please admit that during the period of time wrote insurance for Plaintiff, the only time you were given a name and telephone number of a particular person to contact was if a dispute arose between the insured and .

REQUEST #95: Please admit that maintains a policy of refusing to allow its employees to discuss an insured's insurance with the insured's attorney.

REQUEST #96: Please admit that maintains a policy that requires that the insured give written notice to that the insured consents to discussing the insured's policy with the insured's attorney.

REQUEST #97: Please admit that maintains a policy of not relying on a written statement by an attorney that he/she represents an insured.

REQUEST #98: Please admit that makes no effort to contact the insured regarding the authority of an attorney to discuss his/her policy.

REQUEST #99: Please admit that policy referred to in Request # if same existed is burdensome to insureds.

REQUEST #100: Please admit that policy referred to in Request # if same existed is burdensome to insureds.

REQUEST #101: Please admit that you reapplied to the National Counsel Compensation Insurance for Worker's Compensation insurance on , after cancellation by on .

REQUEST #102: Please admit that Plaintiff relied upon you to acquire Worker's Compensation coverage after terminated his/her coverage.

REQUEST #103: Please admit that you failed to properly complete the application for Worker's Compensation coverage after cancellation with .

REQUEST #104: Please admit that you failed to enclose a deposit with the Worker's Compensation Application mailed to the counsel after cancellation of the policy.

REQUEST #105: Please admit that did not signed the application which was reportedly signed by him/her for the Worker's Compensation coverage.

REQUEST #106: Please admit that did not authorize you to sign his/her name to the Worker's Compensation Application.

REQUEST #107: Please admit that if the Worker's Compensation Application had been properly completed, signed and a deposit premium enclosed, that coverage would have been bound for .

REQUEST #108: Please admit that if the deposit premium had been enclosed that coverage would have been bound for regardless of the correctness of the application.

REQUEST #109: Please admit that you did not invoice Plaintiff for the Worker's Compensation deposit premium until .

REQUEST #110: Please admit that you did not advise Plaintiff that applications were being submitted for Worker's Compensation coverage in . Please admit that did not advise Plaintiff that the disputed premiums must be paid and the dispute resolved later in order to avoid cancellation.

REQUEST #111: Please admit that you advised Plaintiff that its Worker's Compensation coverage would not lapse.

REQUEST #112: Please admit that you advised Plaintiff that there would be no gap between policies wherein it would be without Worker's Compensation coverage.

REQUEST #113: Please admit that Plaintiff did not learn that it had experienced a gap in Worker's Compensation coverage until claims filed which accrued between and were denied.

REQUEST #114: Please admit that Plaintiff attempted to negotiate in good faith with regarding premiums alleged were due on its Worker's Compensation Policy.

REQUEST #115: Please admit that overcharged Plaintiff for Worker's Compensation coverage by approximately $ due to erroneous modification rate.

Respectfully submitted,

Attorney for

Of Counsel:

Telephone:

MSB #

Attorney for

Signature

Verify by signature

What Rule 36 Requests for Admission Are

Rule 36 Requests for Admission are a discovery tool under the Federal Rules of Civil Procedure (Rule 36) that allow one party to ask another to admit the truth of facts, the genuineness of documents, or the application of law to fact. Admissions simplify trials by narrowing disputed issues: a matter admitted is conclusively established unless the court permits withdrawal or amendment. Many state rules provide similar mechanisms under their civil procedure codes, though citation formats and timing can differ between jurisdictions.

Why Requests for Admission Matter in Litigation

Requests for admission reduce litigation scope, focus proof at trial, and can produce binding statements if not timely answered; they are a cost-effective way to eliminate uncontested facts before trial or motion practice.

Who Typically Prepares or Responds to Rule 36 Requests

Parties and attorneys use Rule 36 to lock in facts or challenge opponent positions during discovery.

Plaintiffs and defendants seeking to narrow dispute issues quickly and efficiently.
Litigation attorneys using admissions to support summary judgment or limit trial evidence.
Corporate litigation teams coordinating internal review and factual sign-offs before responding.

Strategic use by either side can shorten proceedings and reduce trial preparation costs.

Core Elements of a Professional Rule 36 Request

A well-drafted request is precise, numbered, limited to a single proposition per request, cites documents when needed, and sets a clear deadline for response consistent with local rules.

Caption

Case caption and court identification exactly matching pleadings so the request is properly noticed and tied to the case record.

Numbering

Sequential, single-issue numbering for each request so answers are unambiguous and easy to reference in briefing or trial exhibits.

Plain Language

Concise, factual wording that avoids compound propositions, legal conclusions, or argumentative phrasing that invite objections.

Document References

If admitting a document’s genuineness, attach or identify it clearly by exhibit label, date, and source for straightforward authentication.

Time Frame

Specify the relevant timeframe in the request to avoid overly broad or vague admissions that opponents can contest.

Response Instructions

State the response method (admit/deny/qualified admission) and identify if partial admissions require explanation or additional facts.

Step-by-Step: How to Draft and Serve a Request

Follow these sequential steps to prepare, serve, and preserve requests and responses under local and federal rules.

01

Draft: Formulate focused, numbered requests tied to evidence and pleadings.
02

Review: Have counsel confirm scope, relevance, and privilege considerations.
03

Serve: Serve on opposing counsel per local rules and proof-of-service requirements.
04

Preserve: Keep copies, service proof, and a logging mechanism for follow-up and motion practice.

How Requests and Responses Flow in Practice

The procedural flow typically moves from drafting to service to response, then to motions to deem or withdraw admissions when disputes arise.

Drafting: Identify facts to narrow, attach supporting documents where applicable.
Service: Deliver via permitted methods and record proof of service.
Response: Respond within the rule period by admitting, denying, or objecting.
Enforcement: File motions if admissions are evasive or withdrawn improperly.

Setting Up an Online Workflow for Requests and Responses

Design an online workflow that assigns drafting, approval, service, and response tracking so nothing is missed during discovery.

Template	Create a reusable template with caption, numbering, and signature block for consistency.
Authentication	Choose signer authentication level (email link, SMS code, or higher KBA) for served responses.
Service Method	Record method and timestamp for service per local rules to prove compliance.
Reminders	Automate reminders ahead of the response deadline to reduce deemed-admission risk.
Audit Trail	Preserve IP, timestamp, and action logs for later evidentiary use.

Technical Requirements for eSubmission and eSignatures

Preserve exportable records and compliance logs so responses and service proofs remain reproducible for court filings and audits.

File Formats: PDF and DOCX supported for attachments and exhibits.
Authentication: Email link or SMS code with optional KBA for stronger verification.
Audit Capability: Platform must capture IP, timestamp, and signer attribution.

Typical Deadlines and Timing Rules

Deadlines vary by jurisdiction, but the federal rule sets a baseline response period and many courts mirror that schedule.

Federal Response Period:

30 days after service under Federal Rules of Civil Procedure Rule 36(a)(3).

Court Extensions:

Courts may shorten or extend deadlines for good cause or stipulation.

Deemed Admissions:

Failure to timely respond can result in matters being deemed admitted by operation of Rule 36.

Withdrawal Motion:

Rule 36(b) allows withdrawal or amendment where justice requires objection.

State Variations:

State rules often mirror federal timing but verify local civil procedure rules for differences.

Common Drafting and Response Pitfalls to Avoid

Asking compound or ambiguous questions that invite objections and motion practice rather than clear admissions.
Attaching documents without specific reference, causing authentication disputes and preventable objections.
Missing the deadline or failing to preserve service proof, which can create deemed admissions.
Using broad legal conclusions rather than narrow factual propositions that courts will consider admitted or contested.

Essential Information Every Request and Response Should Include

Case Caption: Court and docket

Party Names: Full legal names

Request Text: Single factual statement

Exhibit ID: Exhibit label/date

Service Proof: Date/time/method

Responder Info: Name and counsel

Consequences of Improper or Untimely Responses

Deemed Admission: Conclusive on the issue

Motion Practice: Expensive briefing

Estoppel: Limits later defenses

Sanctions: Possible court sanctions

Evidence Loss: Cannot re-litigate admitted fact

Trial Impact: Narrowed defenses at trial

Illustrative Use Cases from Practice

Real-world examples show how focused admissions can resolve issues before trial and avoid unnecessary motion costs.

Case Study 1

A plaintiff served 20 narrow requests aimed at element facts

Opposing party admitted 12 requests
The plaintiff used admissions in a motion that narrowed issues and avoided two days of trial testimony.

Case Study 2

A defense team authenticated key contract pages with requests to admit genuineness

The plaintiff objected broadly
The court ordered precise stipulations and denied an evidentiary hearing, saving time and fees.

Practical Tips for Accurate and Efficient Use

Adopt clear drafting conventions and an organized response process to reduce disputes and litigation costs.

Limit Scope

Focus each request on a single, narrowly tailored fact to minimize objections and increase enforceability.

Attach Exhibits

Where document authenticity is required, include clear exhibit labels and references to avoid authentication disputes.

Meet-and-Confer

Engage opposing counsel early to resolve wording and procedural issues before motions are necessary.

Track Responses

Use a discovery log with deadlines and audit trails to prevent accidental deemed admissions or missed motions.

eSignature Platform Pricing and Feature Snapshot for Discovery Workflows

When choosing an eSignature or e‑service platform, compare starting price, trial availability, bulk send, audit trail capability, HIPAA compliance, and envelope or session limits relevant to discovery needs.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	Yes, 7-day free trial	Yes	Yes	Yes	Yes
Bulk Send	Yes	Yes	Yes	Yes	No
Audit Trail	Yes	Yes	Yes	Yes	Yes
HIPAA Compliant	Yes	Yes	Yes	No	No

Frequently Asked Questions About Rule 36 Requests

Answers to common procedural and tactical questions about drafting, serving, and responding to admissions under federal and state rules.

Need help? Contact support

What happens if I do not respond?
If you fail to respond within the time set by the rule, the matters alleged may be deemed admitted. A court may permit withdrawal, but courts apply Rule 36(b) standards and consider prejudice and the merits of withdrawal.
Can admissions be withdrawn later?
Yes; courts may allow amendment or withdrawal under Rule 36(b) where it serves justice. Courts weigh the nature of the admission, prejudice to the requesting party, and the reason for late change.
Are objections alone sufficient?
An objection without a timely answer can lead to adverse consequences. Responding parties should lodge timely objections and, where required, provide partial answers or qualified admissions to avoid automatic admissions.
Can e-signatures be used on responses?
Electronic signatures are generally valid under the ESIGN Act (15 U.S.C. ch. 96) and state UETA statutes, provided intent, consent, attribution, and reliable record retention are satisfied.
How to authenticate attached documents?
Attach clear exhibit labels and source metadata; requests can ask the opponent to admit genuineness. Authentication is easier when documents include external identifiers like recorded instrument numbers.
What security records should I keep?
Retain service proofs, audit logs, timestamps, and preserved originals. Maintain these records for the duration of litigation and any applicable post-resolution retention periods.

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