Requests for admission ask the other side to admit or deny specific factual statements. Unlike interrogatories, they're not meant to gather new information — they're meant to eliminate what isn't actually disputed.
Write single, unambiguous statements
Each request should state one clear fact that can only reasonably be admitted or denied. Compound or ambiguous statements give the other side an easy way to qualify or dodge the answer.
A non-response can count as an admission
In most jurisdictions, failing to respond within the deadline results in the matter being deemed admitted — which makes these requests a powerful, sometimes underused tool when the other side is slow or disorganized.
Use them to authenticate documents
Requests confirming a document is genuine, or that a signature is authentic, can eliminate the need for costly authentication testimony at trial — a practical, often-overlooked use of this discovery tool.
Save the close calls for trial
Requests aimed at genuinely disputed core facts usually just get denied and waste the tool. Requests are most effective aimed at peripheral or clearly true facts that shouldn't need to be proven at trial.