Objections and Responses to Requests for Admission
(WA)

Summary

This template is a response to requests for admission in a civil action in Washington superior court. This template illustrates the general structure of a response document and includes common forms of objections and responses. This template includes practical guidance and drafting notes. Requests for admission (RFAs) are used to establish matters about which there is no real dispute. RFAs can be particularly helpful in streamlining the litigation by eliminating unnecessary proof, thereby saving litigants time and money. By narrowing the matters that are truly at issue, RFAs may also help facilitate settlement. A RFA may relate to any of the following matters: • Statements or opinions of fact • The application of law to fact • The genuineness of documents Wash. CR 36(a) A matter set forth in a RFA is admitted unless the responding party serves a written response or objection within 30 days after service of the request (unless the court orders a shorter or longer time for response). But a defendant may not be required to serve answers or objections before the expiration of 40 days after service of the summons and complaint upon the defendant. Wash. CR 36(a). Matters that are admitted in the response or deemed admitted by failure to respond are conclusively established for purposes of the lawsuit, unless the court permits and amendment or withdrawal of the admission. See Wash. CR 36(b). Each request in the RFA document should be separately responded to. The standard format for responding to RFAs is to set forth each request verbatim and then insert the response or objection to that request immediately thereafter. To facilitate this process, parties commonly stipulate that the requesting party will provide the responding party with an electronic copy of the RFA document in word processing format. The responding party then copies the requests into a separate word processing file and inserts the responses or objections. The document should also comply with general format requirements for litigation documents, as well as any format requirements contained in local rules. See Formatting Rules in Court Checklist (WA). The response should be served on the requesting party's attorney, or directly on the requesting party if not represented. See Wash. CR 5(a), (b). RFAs and responses should not be filed with the court unless needed for a proceeding (e.g., a discovery motion) or at trial. See Wash. CR 5(i). If filed for use in a proceeding such as a motion, only the portion(s) the party relies on should be filed. See Wash. CR 26(h). For discussion of procedures for serving and filing litigation documents generally, see Filing and Serving Documents Other Than Initial Complaint and Summons (WA). For additional discussion of responding to RFAs, see Requests for Admission: Responding to RFAs (WA).