Request for Admissions Regarding Facts

Contact the Law Office of KENNETH A VERCAMMEN for Legal Representation Kenneth Vercammen, Esq. handles Civil cases where the damages exceed $15,000. Under the NJ Court Rules, in contested Civil cases we recommend our clients prepare short single sentence list of 10-50 sets of "facts", which the adversary should be required to admit. This is part of what is called "discovery." Court Rule 4:22-1. sets forth the Rule on Request for Admission: A party may serve upon any other party a written request for the admission, for purposes of the pending action only, of the truth of any matters of fact within the scope of R. 4:10-2 set forth in the request, including the genuineness of any documents described in the request. Copies of the documents shall be served with the request unless they have been or are otherwise furnished or made available for inspection and copying. The request may, without leave of court, be served upon the plaintiff after commencement of the action and upon any other party with or after service of the summons and complaint upon that party. Each matter of which an admission is requested shall be separately set forth. The matter is admitted unless, within 30 days after service of the request, or within such shorter or longer time as the court may allow, the party to whom the request is directed serves upon the party requesting the admission a written answer or objection addressed to the matter, signed by the party or by the party's attorney. If objection is made, the reasons therefor shall be stated. 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. A denial shall fairly meet the substance of the requested admission, and when good faith requires that a party qualify the answer or deny only a part of the matter of which an admission is requested, the party shall specify so much of it as is true and qualify or deny the remainder. An answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless stating that a reasonable inquiry was made and that the information known or readily obtainable is insufficient to enable an admission or denial. A party who considers that a matter of which an admission has been requested presents a genuine issue for trial, may not, on that ground alone, object to the request but may, subject to the provisions of R. 4:23-3, deny the matter or set forth reasons for not being able to admit or deny. When we serve the Request for Admissions, the individual statements should be written so that the opposing side must Answer "admit" after each one. The following is the start of our form Request for Admissions. PLEASE TAKE NOTICE that the plaintiff demands of the above defendants answers under oath to the following Requests for Admissions within 30 days which is the time prescribed by law. Pursuant to Rule 4:22-1, an answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless he states that he has made reasonable inquiry and that the information known or readily obtainable by him or her is insufficient to enable him to admit or deny. Any request not properly responded to shall be deemed admitted, pursuant to R. 4:22-1. 1. The accident occurred on ......