REQUESTS FOR ADMISSION — EMPLOYMENT

IN THE [________________________________] COURT
[____] JUDICIAL DISTRICT / DIVISION
[________________________________] COUNTY, [____] (STATE)

PROPOUNDING PARTY INFORMATION

PRELIMINARY STATEMENT

Pursuant to Federal Rule of Civil Procedure 36 (or the applicable state procedural rule), the Propounding Party hereby requests that the Responding Party admit the truth of the following matters within thirty (30) days of service, or within the time prescribed by applicable rules.

CRITICAL: DEEMED-ADMITTED CONSEQUENCES. Under Fed. R. Civ. P. 36(a)(3), a matter is deemed admitted unless, within 30 days after being served, the Responding Party serves a written answer or objection addressed to the matter and signed by the party or its attorney. A matter admitted under Rule 36 is conclusively established unless the court, on motion, permits the admission to be withdrawn or amended under Rule 36(b). Failure to timely respond results in automatic admission. Admissions are binding for the pending action but not for any other purpose. See Fed. R. Civ. P. 36(b).

INSTRUCTIONS FOR RESPONDING

1. Requirement to Respond. Each request must be separately answered within thirty (30) days of service. Failure to respond within the time allowed results in automatic admission of the matter. See Fed. R. Civ. P. 36(a)(3).

2. Form of Answers. If a matter is not admitted, the answer must specifically deny it or state in detail why the answering party cannot truthfully admit or deny it. A denial must fairly respond to the substance of the matter. See Fed. R. Civ. P. 36(a)(4).

3. Partial Admissions. When good faith requires that a party qualify an answer or deny only part of a matter, the answer must specify the part admitted and qualify or deny the rest. See Fed. R. Civ. P. 36(a)(4).

4. Lack of Information. The answering party may assert lack of knowledge or information as a reason for failing to admit or deny only if the party states that it has made reasonable inquiry and that the information it knows or can readily obtain is insufficient to enable it to admit or deny. See Fed. R. Civ. P. 36(a)(4).

5. Objections. The grounds for objecting must be stated with specificity. A party must not object solely on the ground that the request presents a genuine issue for trial. See Fed. R. Civ. P. 36(a)(5).

6. Document Authenticity. These requests include requests to authenticate documents. The genuineness of a document is admitted unless specifically denied. An answer to a request for admission of the genuineness of a document is not an admission that the document is admissible in evidence. See Fed. R. Civ. P. 36(a)(1)(B).

7. Effect of Admissions. A matter admitted under Rule 36 is conclusively established unless the court, on motion, permits the admission to be withdrawn or amended. The court may permit withdrawal or amendment if it would promote the presentation of the merits and the party who obtained the admission fails to satisfy the court that withdrawal or amendment would prejudice that party. See Fed. R. Civ. P. 36(b).

8. Cost of Proving Admitted Matters. If a party fails to admit a matter and the requesting party later proves it, the requesting party may move for reasonable expenses, including attorneys' fees, incurred in making that proof. See Fed. R. Civ. P. 37(c)(2).

DEFINITIONS

As used in these requests, the following terms have the meanings set forth below:

1. "PLAINTIFF" means [________________________________].

2. "DEFENDANT" means [________________________________], including all parent, subsidiary, and affiliated companies, and all current and former officers, directors, managers, supervisors, agents, employees, and representatives.

3. "YOU" or "YOUR" refers to the Responding Party.

4. "DOCUMENT" has the broadest meaning permitted under Fed. R. Civ. P. 34(a) and includes all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information, and other data compilations stored in any medium.

5. "ADVERSE ACTION" means any termination, demotion, suspension, reduction in pay or benefits, failure to promote, failure to hire, transfer, reassignment, negative performance evaluation, written warning, disciplinary action, constructive discharge, or any other action that materially affects the terms, conditions, or privileges of employment.

6. "PROTECTED ACTIVITY" means any complaint, report, charge, lawsuit, testimony, refusal to participate in unlawful activity, request for accommodation, request for FMLA leave, or other activity protected by federal, state, or local anti-discrimination, anti-retaliation, or whistleblower statutes.

7. "RELEVANT TIME PERIOD" means the period from [__/__/____] through the present, unless a different time period is specified.

REQUESTS FOR ADMISSION

PART A: EMPLOYMENT RELATIONSHIP

REQUEST NO. 1: Admit that Plaintiff was employed by Defendant from [__/__/____] to [__/__/____].

REQUEST NO. 2: Admit that Plaintiff held the position of [________________________________] during Plaintiff's employment with Defendant.

REQUEST NO. 3: Admit that Plaintiff's duties in the position of [________________________________] included [________________________________].

REQUEST NO. 4: Admit that Plaintiff reported directly to [________________________________] during the period [__/__/____] through [__/__/____].

REQUEST NO. 5: Admit that Plaintiff was classified as a [☐ full-time / ☐ part-time / ☐ exempt / ☐ non-exempt] employee.

REQUEST NO. 6: Admit that Plaintiff was an employee and not an independent contractor during the Relevant Time Period.

REQUEST NO. 7: Admit that Defendant employed fifteen (15) or more employees during the Relevant Time Period for purposes of Title VII coverage.

REQUEST NO. 8: Admit that Defendant employed twenty (20) or more employees during the Relevant Time Period for purposes of ADEA coverage.

REQUEST NO. 9: Admit that Defendant is an "employer" as defined by [Title VII / ADA / ADEA / FMLA / FLSA] [select applicable statute(s)].

REQUEST NO. 10: Admit that [________________________________] (supervisor/decision-maker) was acting within the scope of employment when taking actions described in Plaintiff's complaint.

PART B: JOB PERFORMANCE

REQUEST NO. 11: Admit that Plaintiff received a satisfactory or above-satisfactory performance evaluation for the period ending [__/__/____].

REQUEST NO. 12: Admit that Plaintiff met or exceeded the performance expectations for the position of [________________________________] during the period [__/__/____] through [__/__/____].

REQUEST NO. 13: Admit that Plaintiff was not placed on any performance improvement plan before [__/__/____].

REQUEST NO. 14: Admit that Plaintiff received no written warnings or disciplinary actions before [__/__/____].

REQUEST NO. 15: Admit that Plaintiff received [a raise / a bonus / a promotion / a positive performance review] on or about [__/__/____].

REQUEST NO. 16: Admit that Plaintiff's most recent performance evaluation before the adverse action did not identify the performance issues cited as the basis for the adverse action.

REQUEST NO. 17: Admit that no supervisor documented any performance deficiency on the part of Plaintiff before [__/__/____].

REQUEST NO. 18: Admit that Plaintiff successfully completed the probationary period for the position of [________________________________].

PART C: POLICIES AND PROCEDURES

REQUEST NO. 19: Admit that Defendant maintained a written anti-discrimination policy during the Relevant Time Period.

REQUEST NO. 20: Admit that Defendant maintained a written anti-harassment policy during the Relevant Time Period.

REQUEST NO. 21: Admit that Defendant maintained a written anti-retaliation policy during the Relevant Time Period.

REQUEST NO. 22: Admit that the employee handbook in effect on [__/__/____] contained a procedure for employees to report complaints of discrimination, harassment, or retaliation.

REQUEST NO. 23: Admit that Defendant's anti-discrimination policy required Defendant to investigate all complaints of discrimination.

REQUEST NO. 24: Admit that Defendant's progressive discipline policy required that employees receive [verbal warning / written warning / final written warning] before termination, except in cases of gross misconduct.

REQUEST NO. 25: Admit that Defendant did not follow its own progressive discipline policy with respect to Plaintiff.

REQUEST NO. 26: Admit that the employee handbook attached hereto as Exhibit [____] is a true and correct copy of the handbook in effect during Plaintiff's employment.

REQUEST NO. 27: Admit that Defendant provided mandatory anti-discrimination or anti-harassment training during the Relevant Time Period.

REQUEST NO. 28: Admit that [________________________________] (accused supervisor/harasser) attended anti-discrimination or anti-harassment training on or before [__/__/____].

PART D: ADVERSE ACTIONS

REQUEST NO. 29: Admit that Plaintiff was [terminated / demoted / suspended / denied promotion / transferred / subjected to other adverse action] on or about [__/__/____].

REQUEST NO. 30: Admit that [________________________________] (decision-maker name) made or recommended the decision to [terminate / demote / suspend / deny promotion to] Plaintiff.

REQUEST NO. 31: Admit that the reason given to Plaintiff for the adverse action was [________________________________].

REQUEST NO. 32: Admit that no written documentation supporting the stated reason for the adverse action existed before [__/__/____].

REQUEST NO. 33: Admit that the adverse action against Plaintiff occurred within [____] days/months of Plaintiff's protected activity.

REQUEST NO. 34: Admit that before the adverse action, Plaintiff had not been informed that [his/her/their] job was in jeopardy.

REQUEST NO. 35: Admit that the position held by Plaintiff was filled by [________________________________] after Plaintiff's separation.

REQUEST NO. 36: Admit that [________________________________] (replacement) is not a member of Plaintiff's protected class with respect to [race/sex/age/disability/religion/national origin].

REQUEST NO. 37: Admit that Plaintiff's replacement had less experience or fewer qualifications than Plaintiff at the time of replacement.

REQUEST NO. 38: Admit that Defendant offered Plaintiff a severance agreement in connection with the adverse action.

REQUEST NO. 39: Admit that the severance agreement offered to Plaintiff contained a release of claims.

PART E: COMPARATOR TREATMENT

REQUEST NO. 40: Admit that [________________________________] (comparator name) held the same or a substantially similar position as Plaintiff.

REQUEST NO. 41: Admit that [________________________________] (comparator) reported to the same supervisor as Plaintiff.

REQUEST NO. 42: Admit that [________________________________] (comparator) engaged in the same or similar conduct as that attributed to Plaintiff as a basis for adverse action.

REQUEST NO. 43: Admit that [________________________________] (comparator) was not [terminated / disciplined / demoted] for the same or similar conduct.

REQUEST NO. 44: Admit that [________________________________] (comparator) is not a member of Plaintiff's protected class with respect to [race/sex/age/disability/religion/national origin].

REQUEST NO. 45: Admit that Defendant treated [________________________________] (comparator) more favorably than Plaintiff with respect to [discipline / promotions / work assignments / scheduling / compensation].

REQUEST NO. 46: Admit that during the Relevant Time Period, no employee outside Plaintiff's protected class was [terminated / disciplined / denied promotion] for the conduct attributed to Plaintiff.

PART F: COMPLAINTS AND REPORTING

REQUEST NO. 47: Admit that Plaintiff complained to [________________________________] about [discrimination / harassment / retaliation / hostile work environment] on or about [__/__/____].

REQUEST NO. 48: Admit that Defendant received Plaintiff's complaint and was on notice of the allegations before the adverse action.

REQUEST NO. 49: Admit that [________________________________] (decision-maker) was aware of Plaintiff's complaint before making the adverse employment decision.

REQUEST NO. 50: Admit that Defendant did not conduct an investigation into Plaintiff's complaint within [____] days of receiving it.

REQUEST NO. 51: Admit that the investigation into Plaintiff's complaint was conducted by [________________________________], who reported to the same manager as the accused.

REQUEST NO. 52: Admit that the investigation into Plaintiff's complaint did not include interviews of all witnesses identified by Plaintiff.

REQUEST NO. 53: Admit that Defendant did not provide Plaintiff with the results of the investigation into Plaintiff's complaint.

REQUEST NO. 54: Admit that Defendant took no corrective action against [________________________________] (accused person) following the investigation.

PART G: EEOC AND ADMINISTRATIVE PROCEEDINGS

REQUEST NO. 55: Admit that Plaintiff filed a Charge of Discrimination with the EEOC on or about [__/__/____].

REQUEST NO. 56: Admit that the EEOC issued a Right to Sue letter to Plaintiff on or about [__/__/____].

REQUEST NO. 57: Admit that Defendant received notice of Plaintiff's EEOC Charge on or about [__/__/____].

REQUEST NO. 58: Admit that Defendant submitted a Position Statement to the EEOC in response to Plaintiff's Charge.

REQUEST NO. 59: Admit that other employees filed Charges of Discrimination with the EEOC against Defendant during the Relevant Time Period.

PART H: DAMAGES

REQUEST NO. 60: Admit that Plaintiff's annual base salary at the time of the adverse action was $[________________________________].

REQUEST NO. 61: Admit that Plaintiff was entitled to the following benefits at the time of the adverse action: [health insurance / retirement contributions / bonuses / stock options / other: ________________________________].

REQUEST NO. 62: Admit that Plaintiff has not been employed in a position with equivalent compensation since the adverse action.

REQUEST NO. 63: Admit that Plaintiff incurred medical or counseling expenses as a result of the conduct alleged in this action.

REQUEST NO. 64: Admit that Defendant has not paid Plaintiff any back pay or other compensation since the adverse action.

REQUEST NO. 65: Admit that Plaintiff timely applied for unemployment benefits following the adverse action.

PART I: COMMUNICATIONS AND DOCUMENTS

REQUEST NO. 66: Admit that the email dated [__/__/____] from [________________________________] to [________________________________], a copy of which is attached hereto as Exhibit [____], is a true and correct copy of an email sent and received through Defendant's email system.

REQUEST NO. 67: Admit that the text message(s) dated [__/__/____] between [________________________________] and [________________________________], copies of which are attached hereto as Exhibit [____], are true and correct copies.

REQUEST NO. 68: Admit that the performance evaluation dated [__/__/____], a copy of which is attached hereto as Exhibit [____], is a true and correct copy of Plaintiff's performance evaluation prepared by [________________________________].

REQUEST NO. 69: Admit that the termination letter dated [__/__/____], a copy of which is attached hereto as Exhibit [____], is a true and correct copy of the letter provided to Plaintiff.

REQUEST NO. 70: Admit that the disciplinary notice dated [__/__/____], a copy of which is attached hereto as Exhibit [____], is a true and correct copy of a record from Plaintiff's personnel file.

REQUEST NO. 71: Admit that Defendant maintains personnel files for its employees, including Plaintiff.

REQUEST NO. 72: Admit that Defendant's records reflect that no written disciplinary action was taken against Plaintiff before [__/__/____].

PART J: DISABILITY AND ACCOMMODATION (ADA)

REQUEST NO. 73: Admit that Plaintiff requested a reasonable accommodation on or about [__/__/____].

REQUEST NO. 74: Admit that Plaintiff's requested accommodation was [________________________________].

REQUEST NO. 75: Admit that Defendant did not engage in the interactive process as required by the ADA after receiving Plaintiff's accommodation request.

REQUEST NO. 76: Admit that the accommodation requested by Plaintiff would not have imposed an undue hardship on Defendant.

REQUEST NO. 77: Admit that Plaintiff was able to perform the essential functions of the position of [________________________________] with or without reasonable accommodation.

PART K: FMLA LEAVE

REQUEST NO. 78: Admit that Plaintiff requested FMLA leave on or about [__/__/____].

REQUEST NO. 79: Admit that Plaintiff was eligible for FMLA leave at the time of the request.

REQUEST NO. 80: Admit that Defendant did not restore Plaintiff to the same or an equivalent position upon Plaintiff's return from FMLA leave.

STATE-SPECIFIC PRACTICE NOTES

California

• No Numeric Limit on RFAs: California does not impose a numerical limit on requests for admission. However, the court may limit RFAs if they are unduly burdensome. See Cal. Code Civ. Proc. (CCP) Section 2033.010 et seq.
• Response Time: 30 days from service; 35 days if served by mail within California. See CCP Section 2033.250.
• Deemed Admitted: If a party fails to serve a timely response, the requesting party may move for an order that the genuineness of documents and the truth of matters specified in the requests be deemed admitted. See CCP Section 2033.280.
• Cost of Proof: If a party fails to admit a matter and the requesting party later proves it, the court shall order the non-admitting party to pay reasonable expenses of proof unless there was a reasonable ground for the failure. See CCP Section 2033.420.

Texas

• No Express Limit: Texas Rule of Civil Procedure 198 does not impose a specific numeric limit on requests for admission at Level 2 discovery. However, all discovery is subject to the proportionality limitations of Tex. R. Civ. P. 192.4.
• Response Time: 30 days from service. See Tex. R. Civ. P. 198.2(a).
• Deemed Admitted: If a response is not timely served, the request is considered admitted without the necessity of a court order. See Tex. R. Civ. P. 198.2(c).
• Withdrawal: A party may withdraw an admission with leave of court if the party shows good cause and the withdrawal will not unduly prejudice the requesting party. See Tex. R. Civ. P. 198.3.

Florida

• No Express Limit: Florida Rule of Civil Procedure 1.370 does not impose a numeric limit on requests for admission.
• Response Time: 30 days from service; 45 days for a defendant served before answer is due. See Fla. R. Civ. P. 1.370(a).
• Deemed Admitted: Matters are deemed admitted if a written answer or objection is not served within the time limit. See Fla. R. Civ. P. 1.370(a).
• Sufficiency of Answers: The party who has requested the admissions may move to determine the sufficiency of the answers or objections. See Fla. R. Civ. P. 1.370(a).

New York

• No Express Limit: CPLR Section 3123 does not impose a numeric limit on requests for admission (called "notice to admit" in New York practice).
• Response Time: 20 days from service. See CPLR Section 3123(a).
• Deemed Admitted: Each matter of which an admission is requested is deemed admitted unless the party to whom the request is directed serves a sworn statement either denying specifically the matters or setting forth in detail the reasons why the party cannot truthfully admit or deny. See CPLR Section 3123(a).
• Scope Limitation: A notice to admit may not be used to request admission of material issues in the action. New York courts have been stricter in limiting the scope of notices to admit. See CPLR Section 3123(a).

VERIFICATION

I, [________________________________], declare under penalty of perjury under the laws of [________________________________] (state) and of the United States that the foregoing responses are true and correct to the best of my knowledge, information, and belief.

☐ Responding Party is an individual
☐ Responding Party is a corporate officer or authorized agent

Executed on: [__/__/____]

At: [________________________________] (City, State)

_______________________________________________
[RESPONDING PARTY NAME — Printed]

_______________________________________________
[SIGNATURE]

Title (if corporate representative): [________________________________]

CERTIFICATE OF SERVICE

I, [________________________________], hereby certify that on [__/__/____], I served the foregoing REQUESTS FOR ADMISSION — EMPLOYMENT upon all counsel of record by the following method:

☐ Electronic filing (ECF/e-filing system)
☐ Email to: [________________________________]
☐ U.S. Mail, first class, postage prepaid
☐ Hand delivery
☐ Overnight courier

Served upon:

[________________________________]
[________________________________]
[________________________________]
[________________________________]
[________________________________]

_______________________________________________
[ATTORNEY NAME]
[FIRM NAME]
[ADDRESS]
[CITY, STATE ZIP]
[PHONE]
[EMAIL]
[BAR NUMBER]
Attorney for [________________________________]

SOURCES AND REFERENCES

• Federal Rules of Civil Procedure, Rule 36 — https://www.law.cornell.edu/rules/frcp/rule_36
• Federal Rules of Civil Procedure, Rule 37(c)(2) (Failure to Admit) — https://www.law.cornell.edu/rules/frcp/rule_37
• Title VII of the Civil Rights Act of 1964, 42 U.S.C. Section 2000e et seq.
• Americans with Disabilities Act (ADA), 42 U.S.C. Section 12101 et seq.
• Age Discrimination in Employment Act (ADEA), 29 U.S.C. Section 621 et seq.
• Family and Medical Leave Act (FMLA), 29 U.S.C. Section 2601 et seq.
• California Code of Civil Procedure, Sections 2033.010-2033.420
• Texas Rules of Civil Procedure, Rule 198
• Florida Rules of Civil Procedure, Rule 1.370
• New York CPLR, Section 3123

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in the relevant jurisdiction must review and customize this document before use. Laws and procedural rules vary by jurisdiction and change frequently. Use of this template does not create an attorney-client relationship.

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