Connecticut State Court Requests for Admission

SUPERIOR COURT OF THE STATE OF CONNECTICUT

JUDICIAL DISTRICT OF [________________________________]

AT [________________________________]

Docket No.: [________________________________]

Return Date: [__/__/____]

[PLAINTIFF'S / DEFENDANT'S] FIRST REQUESTS FOR ADMISSION DIRECTED TO [RESPONDING PARTY]

ATTORNEY INFORMATION

Propounding Attorney:

Date of Certification: [__/__/____]

I. INTRODUCTORY STATEMENT

Pursuant to Connecticut Practice Book ("CPB") Sections 13-22 through 13-25 and all other applicable provisions of Connecticut law, [Plaintiff / Defendant] [________________________________] ("Propounding Party") hereby requests that [________________________________] ("Responding Party" or "You") admit, for purposes of this action only, the truth of the matters set forth below, including statements or opinions of fact and the application of law to fact, and the genuineness of the documents identified below.

1. Authority and Scope. Under CPB Section 13-22(a), a party may serve a written request for the admission of the truth of any matters within the scope of CPB Section 13-2 that relate to statements or opinions of fact or of the application of law to fact, including the genuineness of any documents described in the request. Copies of any such documents are served with these Requests unless they have been or are otherwise furnished or made available for inspection and copying.

2. Notice and Filing. Pursuant to CPB Section 13-22(b), these Requests are served on the Responding Party and are not filed with the court; the Propounding Party will instead file a notice with the court stating that these Requests have been served. The time for response runs from the filing of that notice. See CPB Section 13-23(a).

3. Materiality. These Requests seek admissions material to the subject matter of the pending action and within the scope permitted by CPB Section 13-2.

II. DEADLINE FOR RESPONSE AND DEEMED-ADMITTED WARNING

Response Deadline. Pursuant to CPB Section 13-23(a), each matter of which an admission is requested is admitted unless, within thirty (30) days after the filing of the notice required by CPB Section 13-22(b) — or within such shorter or longer time as the judicial authority may allow — the Responding Party files and serves upon the Propounding Party a written answer or objection addressed to the matter, signed by the party or the party's attorney. Any such answer or objection shall be inserted directly on the original request.

WARNING — FAILURE TO RESPOND RESULTS IN ADMISSION. Under CPB Section 13-23(a), any matter for which a written answer or objection is not served within the time allowed is deemed admitted and, under CPB Section 13-24(a), is conclusively established for purposes of this action. No further motion or court order is required for the admission to take effect.

If an objection is made, the reasons therefor must be stated. The answer must specifically deny the matter or set forth in detail the reasons why the answering party cannot truthfully admit or deny it. A denial must fairly meet the substance of the requested admission, and where good faith requires that the answering party qualify an answer or deny only part of a matter, the party must specify so much of it as is true and qualify or deny the remainder. CPB Section 13-23(a).

III. DEFINITIONS

For purposes of these Requests, the following terms shall have the meanings set forth below. These definitions apply regardless of capitalization.

1. "You," "Your," or "Responding Party" means [________________________________], including all present and former parents, subsidiaries, affiliates, divisions, officers, directors, managers, members, partners, employees, agents, representatives, insurers, and attorneys, and all other persons or entities acting or purporting to act on Responding Party's behalf.

2. "Document" or "Documents" has the broadest meaning permissible under the Practice Book, including all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information ("ESI"), and other data or data compilations stored in any medium, including drafts, non-identical copies, and associated metadata.

3. "Communication" means any transmission of information by any means, whether oral, written, or electronic.

4. "Admit" means to acknowledge unequivocally the truth of the matter or the genuineness of the document stated in the Request, without qualification, unless a good-faith qualification is expressly stated as permitted by CPB Section 13-23(a).

5. "Genuine" or "genuineness," as applied to a document, means that the document is what it purports to be, that it was prepared, executed, sent, or received as it appears. Pursuant to CPB Section 13-24(b), an admission of the existence and due execution of a document, unless otherwise expressed, is deemed to include an admission of its delivery and that it has not since been altered.

6. "Concerning" or "Relating to" means referring to, describing, evidencing, constituting, mentioning, reflecting, connected with, commenting on, regarding, or pertaining to, in whole or in part.

7. "Incident" means the events, acts, omissions, and circumstances giving rise to this action, as described in the operative pleadings.

8. "Person" means any natural person, corporation, limited liability company, partnership, association, governmental body, or other legal entity.

IV. INSTRUCTIONS

1. Separate Answer to Each Request. The Responding Party must answer each Request separately and in the same sequence and numbering used here, inserting the answer or objection directly on the original request (or on a separate sheet attached to the response where additional space is required). CPB Section 13-23(a).

2. Reasonable Inquiry. Pursuant to CPB Section 13-23(a), the answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless it states that it has made reasonable inquiry and that the information known or readily obtainable by it is insufficient to enable an admission or denial.

3. Genuine Issue for Trial Not a Bar. 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; the party may deny the matter or set forth the reasons why it cannot admit or deny it. CPB Section 13-23(a).

4. Objections. Pursuant to CPB Section 13-23, any objection must state the reasons therefor with specificity. If only part of a Request is objectionable, the remainder must be answered.

5. Genuineness of Documents. A copy of each document whose genuineness is requested is served with these Requests or has been made available for inspection and copying. Pursuant to CPB Section 13-24(b), the admission of any matter is not deemed to waive any objection to its competency or relevancy at trial.

6. Cover Sheet. Pursuant to CPB Section 13-23(a), the Responding Party shall attach to its response a cover sheet that complies with CPB Sections 4-1 and 4-2 and specifies those Requests to which answers and objections are addressed.

7. Effect of Admission; Conclusively Established. Pursuant to CPB Section 13-24(a), any matter admitted (by answer or by failure to respond) is conclusively established in this action unless the judicial authority, on motion, permits withdrawal or amendment of the admission. An admission is for the purpose of the pending action only and is not an admission for any other purpose, nor may it be used against the Responding Party in any other proceeding.

8. Withdrawal or Amendment. Under CPB Section 13-24(a), the judicial authority may permit withdrawal or amendment of an admission when the presentation of the merits of the action will be subserved thereby and the party who obtained the admission fails to satisfy the court that withdrawal or amendment will prejudice that party in maintaining its action or defense on the merits.

9. Construction. The singular includes the plural and vice versa; "and" and "or" shall be construed conjunctively or disjunctively as necessary to bring within the scope of these Requests all matters that might otherwise be construed outside their scope.

V. REQUESTS FOR ADMISSION — MATTERS OF FACT AND APPLICATION OF LAW TO FACT

REQUEST FOR ADMISSION NO. 1: Admit that the Incident occurred on [__/__/____].

REQUEST FOR ADMISSION NO. 2: Admit that, at the time of the Incident, You were [describe role/relationship].

REQUEST FOR ADMISSION NO. 3: Admit that You [describe conduct alleged, e.g., entered into the agreement attached as Exhibit A].

REQUEST FOR ADMISSION NO. 4: Admit that You received the [document/communication] described in Paragraph [____] of the operative pleading.

REQUEST FOR ADMISSION NO. 5: Admit that You did not [perform the act / make the payment / provide the notice] described in Paragraph [____] of the operative pleading.

REQUEST FOR ADMISSION NO. 6: Admit that the amount of [$____________] remains unpaid under the agreement at issue.

REQUEST FOR ADMISSION NO. 7: Admit that You owed a duty of [care / performance] to Propounding Party with respect to [________________________________].

REQUEST FOR ADMISSION NO. 8: Admit that You breached the duty referenced in Request No. 7.

REQUEST FOR ADMISSION NO. 9: Admit that Propounding Party sustained damages as a result of the Incident.

REQUEST FOR ADMISSION NO. 10: Admit that You have no documents supporting Your special defense of [________________________________].

REQUEST FOR ADMISSION NO. 11: Admit that [describe an application of law to fact, e.g., the agreement attached as Exhibit A is an enforceable contract between You and Propounding Party].

REQUEST FOR ADMISSION NO. 12: [________________________________]

REQUEST FOR ADMISSION NO. 13: [________________________________]

REQUEST FOR ADMISSION NO. 14: [________________________________]

VI. REQUESTS FOR ADMISSION — GENUINENESS AND DUE EXECUTION OF DOCUMENTS

REQUEST FOR ADMISSION NO. 15: Admit that the document attached hereto as Exhibit [____] ([describe]) is genuine.

REQUEST FOR ADMISSION NO. 16: Admit that the document attached hereto as Exhibit [____] is a true and correct copy of the [contract / letter / email / record] dated [__/__/____].

REQUEST FOR ADMISSION NO. 17: Admit the existence and due execution of the document attached hereto as Exhibit [____].

REQUEST FOR ADMISSION NO. 18: Admit that the signature appearing on the document attached hereto as Exhibit [____] is Your signature (or the signature of Your authorized agent).

REQUEST FOR ADMISSION NO. 19: [________________________________]

REQUEST FOR ADMISSION NO. 20: [________________________________]

VII. DEADLINE AND EXPENSES-ON-FAILURE-TO-ADMIT NOTICE

The Responding Party is reminded that a written answer or objection is due within thirty (30) days after the filing of the CPB Section 13-22(b) notice, failing which each matter herein is deemed admitted and conclusively established under CPB Sections 13-23 and 13-24.

Expenses on Failure to Admit. Pursuant to CPB Section 13-25, if the Responding Party fails to admit the genuineness of any document or the truth of any matter requested herein, and the Propounding Party thereafter proves the genuineness of the document or the truth of the matter, the Propounding Party may apply to the court for an order requiring the Responding Party to pay the reasonable expenses incurred in making that proof, including reasonable attorney's fees. The judicial authority shall make the order unless it finds that the failure to admit was reasonable.

VIII. SIGNATURE

Dated: [__/__/____]

Respectfully submitted,

Signature: [________________________________]
[________________________________], Esq.
Counsel for [Propounding Party]
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Juris No.: [________________________________]

IX. CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], a copy of the foregoing [PLAINTIFF'S / DEFENDANT'S] FIRST REQUESTS FOR ADMISSION DIRECTED TO [RESPONDING PARTY] was served upon counsel of record (or upon the party, if self-represented) by the method indicated below, in compliance with Connecticut Practice Book Section 10-12 et seq.:

☐ Hand delivery
☐ First-class United States mail, postage prepaid
☐ Certified mail, return receipt requested
☐ Electronic service via the Judicial Branch e-filing system
☐ Email (by agreement of the parties)
☐ Other: [________________________________]

Served Upon:

[________________________________], Esq.
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Juris No.: [________________________________]

Signature: [________________________________]
[________________________________], Esq.
Counsel for [Propounding Party]
Juris No.: [________________________________]

X. PRACTICE NOTES

1. 30-Day Response Deadline; Automatic Admission. Under CPB Section 13-23(a), a written answer or objection is due within 30 days after the filing of the Section 13-22(b) notice. Any matter not timely answered is deemed admitted and, under Section 13-24(a), conclusively established — no further motion is required. This auto-admission consequence is the defining feature of requests for admission.

2. Notice-and-File Procedure. Connecticut does not file the requests themselves; the propounding party files a notice under Section 13-22(b), and the answers/objections are inserted on the original request and returned to the propounding party. Confirm the local practice and any electronic-filing format requirements.

3. Due Execution Presumption. An admission of the existence and due execution of a document, unless otherwise expressed, includes an admission of its delivery and that it has not since been altered. CPB Section 13-24(b).

4. Reasonable Inquiry. A party may not plead lack of information unless it has made reasonable inquiry and the information known or readily obtainable is insufficient. CPB Section 13-23(a).

5. Withdrawal or Amendment. The judicial authority may permit withdrawal or amendment under the two-part standard in CPB Section 13-24(a) (merits subserved; no prejudice to the party who obtained the admission).

6. Expenses on Failure to Admit. If a denied matter is later proven, the court shall order the responding party to pay the reasonable expenses, including attorney's fees, of making that proof, unless the failure to admit was reasonable. CPB Section 13-25.

7. Cover Sheet. The response must include a cover sheet complying with CPB Sections 4-1 and 4-2 specifying the Requests addressed. CPB Section 13-23(a).

XI. SOURCES AND REFERENCES

• Connecticut Practice Book Section 13-2 — Scope of Discovery
• Connecticut Practice Book Section 13-5 — Protective Orders; Limitations on Discovery
• Connecticut Practice Book Section 13-22 — Admission of Facts and Execution of Writings; Requests for Admission (Scope; Notice)
• Connecticut Practice Book Section 13-23 — Answers and Objections to Requests for Admission; 30-Day Response; Reasonable Inquiry
• Connecticut Practice Book Section 13-24 — Effect of Admission; Conclusively Established; Withdrawal or Amendment; Due Execution
• Connecticut Practice Book Section 13-25 — Expenses on Failure to Admit
• Connecticut Practice Book Section 13-14 — Order for Compliance; Sanctions
• Connecticut Practice Book Section 10-12 et seq. — Service of the Pleadings and Other Papers
• Connecticut Practice Book Sections 4-1, 4-2 — Form of Papers; Cover Sheet
• Connecticut Judicial Branch Official Website: https://www.jud.ct.gov
• Connecticut Practice Book (Current Edition): https://www.jud.ct.gov/publications/PracticeBook/PB.pdf

This template is designed for use in the Connecticut Superior Court. Verify all Practice Book citations, follow the Section 13-22(b) notice-and-file procedure, confirm any applicable Judicial District standing orders and e-filing format requirements, attach copies of any documents whose genuineness is requested, and tailor each request to the specific claims and special defenses at issue. Have the document reviewed by a licensed Connecticut attorney before service.