Draft Requests for Admission to the Defendant in a Personal Injury Case
Drafts single-fact requests for admission that narrow the dispute, each tied to the evidence behind it and the element it helps prove, with the numerical limit and timing left for you to confirm.
The Prompt
Variables (7)
| Variable | Description | Example |
|---|---|---|
| {{court_and_jurisdiction}} | Court and Jurisdiction | District Court, Harris County, Texas (state court) |
| {{governing_discovery_rules}} | Governing Rules on Requests for Admission | Texas Rule of Civil Procedure 198 (text pasted below). Discovery control plan Level 2. Response time and any limit on number: as stated in the pasted text and the scheduling order dated 02/10/2026. |
| {{responding_defendant}} | Responding Defendant | Sunline Logistics LLC |
| {{claims_and_elements}} | Claims and Elements | Negligence against driver: duty, breach, causation, damages. Vicarious liability against employer: employment, course and scope. |
| {{disputed_issues}} | Disputed Issues | Defense disputes signal color and causation of the C5-C6 herniation; ownership of the van and employment are not expected to be contested. |
| {{case_facts_and_evidence}} | Facts and Evidence with Sources | Reyes deposition 01/22/2026, 41:7-12: "I was on a delivery for Sunline." Crash report 24-118733, p. 2: "Unit 1 failed to stop for red signal." Sunline interrogatory answer no. 4 dated 12/03/2025: van owned by Sunline. |
| {{document_list}} | Documents to Authenticate | SUN000112-118 driver log for 03/14/2025; SUN000201 telematics report; PLF000045-052 Banner Health ER record dated 03/14/2025. |
Expected Output
Two parts. Part 1, attorney-only notes: (A) an evidence register with quoted sources; (B) conflicts between sources, both versions quoted; (C) arithmetic recomputed line by line; (D) a table tying each request to its source and the element it serves; (E) a priority ranking with the count and the order in which to cut; (F) unsupported statements declined, with the source each would need; (G) declined requests; (H) missing information. Part 2, the requests as served: numbered single-fact requests grouped as document genuineness, background, liability and damages, free of markers and notes. A verification list closes the output.
Usage Notes
Use after written discovery and key depositions, when you can point to the defendant's own documents and testimony. Paste the rule that governs requests for admission in your court, including any cap and the response time: the prompt will not supply them, and it will not size the set to a limit that only appears in opposing counsel's letter. Failure modes to watch for: a request that adds a date, a time or a causal link its source does not state, and a request that treats one of two conflicting records as the fact; read the conflicts section before serving and check every request against its quoted source. The federal rules listed are reference points only. Read the document part line by line before it leaves the office: in testing, a small model sometimes left an internal remark, a comparison with the file or an unresolved point inside the document despite the instructions. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Legal Sources Referenced
- Fed. R. Civ. P. 36(a)(1) (a party may request admission of the truth of matters relating to facts, the application of law to fact, or opinions about either, and the genuineness of any described documents)
- Fed. R. Civ. P. 36(a)(2) (each matter must be separately stated; a request to admit the genuineness of a document must be accompanied by a copy unless it has been otherwise furnished or made available)
- Fed. R. Civ. P. 36(b) (a matter admitted is conclusively established unless the court, on motion, permits the admission to be withdrawn or amended)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.