Request for Admissions

ABOUT THIS FORM: Request for Admissions

Maryland Rule 2-424 allows parties in civil cases to serve opposing parties with Requests for Admissions (“RFA”). An RFA can ask the opposing party to admit that certain statements of fact are true or to admit that certain documents are true and genuine. A party who is served with an RFA must either admit or deny each request or provide an explanation why the request cannot b admitted or denied. Below is a simple set of Requests for Admissions in an auto tort case. This RFA contains 7 requests asking the defendant (the at-fault driver) to admit to certain fact statements. RFAs can be an effective tool for narrowing down issues, but they have limited evidentiary use at trial.


IN THE CIRCUIT COURT FOR HOWARD COUNTY

MICHAEL SMITH
          Plaintiff,

v.                                                                                Case No.:  19-C-555555

JANE TORTFEASOR
          Defendant.

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PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS

TO:          JANE TORTFEASOR, Defendant
FROM:     MICHAEL SMITH, Plaintiff

Plaintiff Michael Smith (“Plaintiff”), by and through his attorneys, Miller & Zois, LLC, requests that Defendant, admit or deny the following statements of fact.  If objection is made, please state the reason for the objection.

REQUESTS FOR ADDMISSION

      1.   The Defendant was properly served with the summons and complaint in the above captioned case.
      2.   The Defendant has no basis to assert as a defense or affirmative defense to the subject accident, lack of personal jurisdiction.
      3.    The Defendant has no evidence of any kind that the Plaintiff caused or contributed to the occurrence by stopping short in the travel portion of the roadway.
      4.    The Defendant has no evidence to support the affirmative defense that the Plaintiff assumed the risk of his injuries.
      5.    The Defendant has no evidence to support the affirmative defense that the Plaintiff was contributorily negligent.
      6.    The Defendant has no evidence to support the affirmative defense that the Plaintiff’s case is barred by the Statute of Limitations.
      7.    The Defendant has no evidence to support the affirmative defense that the Plaintiff’s case fails to state a claim upon which relief can be granted.
      8.    On or about March 31, 2019, Plaintiff was lawfully operating his vehicle and traveling eastbound on Assateague Drive, in Howard County, Maryland.
      9.    At the same time and place, Defendant was operating a motor vehicle northbound on Conwingo Avenue, attempting a left turn onto westbound Assateague Drive, in Howard County, Maryland.
      10.   At all times herein mentioned the Plaintiff’s vehicle was operated in a reasonable and prudent manner, with due caution and regard for the motor vehicle laws of the State of Maryland.
      11.    Defendant failed to yield to Plaintiff’s right-of-way, failed to control her vehicle, failed to obey traffic control devices, causing Plaintiff’s vehicle to collide with Defendant’s vehicle.
      12.    The intersection was not controlled by a traffic control device.

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FAQs on Request for Admissions

How long do you have to respond to a Request for Admission in Maryland?

Under Maryland Rule 2-424(b) a party served with a Request for Admissions must submit responses within 30 days of the date they are served with the RFA. If the RFA is served before the complaint is answered, responses are due within 15 days after the deadline for filing an answer or initial responsive pleading.

Is there a limit on the number of requests in an RFA in Maryland?

No. Unlike interrogatories and other types of discovery requests, the Maryland rules do not put any maximum limit on the number of individual requests for admission that can be served. This often leads some attorneys to go overboard and propound hundreds of individual requests in an RFA.

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