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Requests for Admissions are essential for obtaining vital information, clarifying issues, and expediting the litigation process.
To assist you, we've created a free, downloadable template for Requests for Admissions in personal injury lawsuits. In accordance with O.C.G.A. §9-11-36, a party may request another party to admit or deny specific “statements or opinions of fact or of the application of law to fact, including the genuineness of any document.”
HOW DO ADMISSIONS AID A PERSONAL INJURY CASE?
Requests for Admissions are invaluable in establishing facts, causation, damages, and more related to the accident in question. Although Plaintiffs' attorneys may overlook requests for admissions due to frequent denials by Defendants, these denials can be advantageous. If a Defendant denies a request for admission concerning a fact or issue that can be easily proven or disclosed otherwise, your client may be entitled to substantial fees and costs associated with modifying or reversing that admission, as per O.C.G.A. §9-11-37.
HOW MANY REQUESTS CAN BE SUBMITTED?
There is no limit on the number of requests for admissions that can be submitted in a personal injury case. These requests can cover various aspects of the accident, treatment, injuries, damages, demand process, negotiations, and even litigation. Moreover, requests can be served at any time, even as early as the initial complaint.
Our template is designed to help personal injury attorneys, like you, to efficiently draft Requests for Admissions, saving time and resources while ensuring a comprehensive and effective discovery process.
Easily tailor the requests to fit the unique needs of your case with this template. To access our free Request for Admissions Template for car accident lawsuits, simply click the link below, provide your name and email address, and we will email you the template:
IN THE STATE COURT OF HALL COUNTY STATE OF GEORGIA
CIVIL ACTION FILE NO.:
PLAINTIFF’S FIRST ADMISSIONS TO DEFENDANT ROBERT SMITH
TO: Robert Smith, Defendant.
FROM: John Smith
Plaintiff, John Smith, by their attorneys, Jennifer Oquendo and Georgia Trial Attorneys at Kirchen & Grant, LLC, requests that the Defendant, Robert Smith, admit or deny, within 30 days of service of these Admissions, the following statements of law in accordance with O.C.G.A. §§ 9-11-26 and 9-11-36 subject to the instructions set forth below:
1. The pronoun “you” and “your” refers to the party to whom the Admissions are addressed and includes knowledge of the party's agents, representatives, and unless privileged, their attorneys and any agents directing this defense on behalf of this party.
2. The term “car crash” is defined as the incident occurring on Saturday, June 5, 2021 between the parties in this action.
3. If objection is made, the answer shall specifically deny the matter or set forth in detail the reasons why the answering party cannot truthfully admit or deny the matter. When a general objection is made to a pleading or evidence as a whole, part of which is not subject to the objection, the entire objection fails in its office as a critic. McDaniel v. Pass, 130 Ga. App. 614, 203 S.E.2d 903 (1974). A general statement that the Defendant can neither admit nor deny, unaccompanied by reasons, will be held an insufficient response and subject to a motion to determine the sufficiency of the answer. It is not sufficient to limit answers to “for want of sufficient information”, the Defendant must provide what information is required to answer the pending request. Gregory v. Vance Publishing Corp., 130 Ga. App. 118 (1973).
4. Plaintiff reminds this party that Request for Admissions pursuant to O.C.G.A. §9-11-36 and Fed. R. 36 “are not objectionable even if [the admission] requires opinions or conclusions of law as long as the legal conclusion relates to the facts of the case.” G.H. Bass & Co. v. Fulton County Bd. Of Tax Assessors, 268 Ga. 327 (1997), Reversing G.H. Bass & Co. v. Fulton County Bd. Of Tax Assessors, 222 Ga. App. 118 (1996).
REQUEST FOR ADMISSIONS
1. Participation. Admit you personally participated in answering each item in these Request for Admissions, Plaintiff’s First Request for Interrogatives, and Plaintiff’s First Request for Production of Documents.
2. Date. Admit the car crash described in the Plaintiff’s complaint occurred on Saturday, June 5, 2021.
3. Location. Admit the car crash occurred at or near the intersection of INTERSECTION DESCRIPTION.
4. Identification. Admit you are properly named in the above-captioned case.
5. Service. Admit you were properly served with the summons and complaint in the above-captioned case as allowed under O.C.G.A. §9-11-4.
6. Personal Jurisdiction. Admit you have no basis to assert as a defense or affirmative defense to this lawsuit, lack of personal jurisdiction over yourself.
7. Subject-matter. Admit you have no basis to assert as a defense or affirmative defense to this lawsuit, lack of subject-matter jurisdiction over this lawsuit.
8. Venue. Admit you have no basis to assert as a defense or affirmative defense to this lawsuit, improper venue.
9. Process. Admit you have no basis to assert as a defense or affirmative defense to this lawsuit, insufficiency of process.
10. Service of Process. Admit you have no basis to assert as a defense or affirmative defense to this lawsuit, insufficiency of service off process.
11. Claim. Admit you have no basis to assert as a defense or affirmative defense to this lawsuit, failure to state a claim upon which relief can be granted.
12. Joinder. Admit you have no basis to assert as a defense or affirmative defense to this lawsuit, failure to join a party under O.C.G.A. §9-11-19 (Joinder of persons needed for just adjudication).
13. Tolling. Admit the issuance of a traffic citation in this case tolls the running of the statute of limitations until the prosecution of the traffic citation becomes final or is otherwise terminated.
14. SOL. Admit you do not contend the Plaintiff’s claims in this lawsuit are barred by expiration of the Statute of Limitations.
15. Repose. Admit you do not contend the Plaintiff’s claims in this lawsuit are barred by expiration of the Statue of Repose.
16. Accord. Admit you do not contend the Plaintiff’s claims in this lawsuit are barred by accord and satisfaction.
17. Arbitrament. Admit you do not contend the Plaintiff’s claims in this lawsuit are barred by an award in arbitration.
18. Assumption. Admit do not contend the Plaintiff assumed the risk of their injuries.
19. Contributory Crash. Admit you do not contend the Plaintiff was contributorily negligent in the causing of the car crash.
20. Contributory Injury. Admit do not contend the Plaintiff was contributorily negligent in...
HAVE QUESTIONS OR NEED ADDITIONAL SUPPORT?
For even more resources and sample documents, explore our comprehensive library featuring valuable tools such as our popular Sample Auto Accident Complaint for Magistrate Court.
We hope our template proves to be a valuable asset in your personal injury practice. If you have any questions or need additional support, don't hesitate to reach out to our experienced team at Georgia Trial Attorneys. Together, we can deliver the best possible outcomes for our clients while upholding the highest standards of personal injury law.