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Illinois Plaintiff's Request for Production of Documents and Request for Admissions

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Multi-State
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US-PI-0279
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This form is a sample of a request for the production of documents and request for admissions propounded to the defendant by the plaintiff in a personal injury action.

Title: Understanding Illinois Plaintiff's Request for Production of Documents and Request for Admissions: A Comprehensive Overview Introduction: The Illinois Plaintiff's Request for Production of Documents and Request for Admissions are essential legal tools used during the pre-trial stage of a lawsuit. These documents enable plaintiffs to gather relevant information, evidence, and admissions from the opposing party, thereby supporting their claims. This article provides a detailed description of these requests, highlighting their purpose, process, and different types in Illinois. 1. Illinois Plaintiff's Request for Production of Documents: The Request for Production of Documents is a formal legal document served by the plaintiff's attorney to the defendant's attorney. It aims to obtain specific documents, records, or physical evidence that could contribute to the case's resolution. Common request categories include: a) Medical Records: Requests for medical records, including diagnostic reports, treatment history, physicians' notes, and related documents, to support claims of injuries or damages. b) Employment Records: Seek pertinent employment-related documents, such as payroll records, performance evaluations, contracts, or correspondence, relevant to employment-related disputes. c) Financial Records: Demand production of financial documents, including tax returns, bank statements, loan agreements, and business records, to assess monetary claims, financial standing, or potential damages. d) Contracts and Agreements: Seek copies of contracts, service agreements, leases, or any legally binding documentation related to the case. e) Communication Records: Request the production of emails, text messages, written correspondence, or phone records that could shed light on disputed conversations or actions. f) Incident Reports: Seek official incident reports, accident reports, or police reports if relevant to the lawsuit. g) Expert Witness Information: Request information regarding any expert witnesses expected to testify for the defendant. 2. Illinois Plaintiff's Request for Admissions: The Request for Admissions is another essential legal tool utilized by plaintiffs in Illinois. It aims to obtain truthful admissions or denials of specific facts from the defendant. By eliciting such admissions, the plaintiff can simplify matters that are not controversial and narrow the scope of the trial. Common areas covered in requests for admissions include: a) Liability: Seek admissions regarding the defendant's negligence, responsibility, or liability related to the case. b) Damages: Request admissions related to the extent and valuation of damages incurred by the defendant's actions. c) Causation: Elicit admissions on the causal link between the defendant's actions and the plaintiff's injuries or damages. d) Facts and Background: Seek admissions on relevant background information, events, or circumstances to establish a factual foundation for the case. Conclusion: The Illinois Plaintiff's Request for Production of Documents and Request for Admissions are crucial components of the pre-trial discovery process. By using these tools effectively, plaintiffs can access essential evidence and admissions, ultimately strengthening their claims. Familiarity with the various types and categories of requests helps plaintiffs to tailor their document requests and admission inquiries strategically, creating a solid foundation for their case.

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(a) Any party may by written request direct any other party to produce for inspection, copying, reproduction photographing, testing or sampling specified documents, including electronically stored information as defined under Rule 201(b)(4), objects or tangible things, or to permit access to real estate for the purpose ...

Also, Federal Rules of Civil Procedure have placed 25 questions per party limitations on the use of interrogatories, but there is no numerical limit in FRCP on the requests for admission (unless specified differently in Local Rules of the state, which most states do have).

A Request for Admission asks the other side in your case to admit that a fact is true or that a document is authentic. If the other side admits that something is true or authentic, you will not need to prove that at trial. This can make your trial faster and less expensive.

Use a Request for Production when you want the other side to produce documents and things as well as a statement under oath that they have provided the documents or things requested, or what they haven't produced and why.

4) Although there are no limits on how many requests you can include in an RFA they must pertain to the claims or defenses in your lawsuit. Consider limiting the content of your RFAs to: ? Whether a fact is true or false. ? How a law or legal principle applies to the facts of your case.

Rule 214 - Discovery of Documents, Objects, and Tangible Things-Inspection of Real Estate (a) Any party may by written request direct any other party to produce for inspection, copying, reproduction photographing, testing or sampling specified documents, including electronically stored information as defined under Rule ...

Rule 216(c) (emphasis added). Illinois Supreme Court Rule 216 requires a party served with requests for admission of facts to either (1) admit, (2) deny or set forth reasons why it cannot fully admit or deny the request or (3) object where the request is improper.

Rule 213 - Written Interrogatories to Parties (a)Directing Interrogatories. A party may direct written interrogatories to any other party. A copy of the interrogatories shall be served on all other parties entitled to notice. (b)Duty of Attorney.

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How to Write a Good Request for Admission: A Second Take. Requests for admissions "can provide a good avenue in which to firmly establish undisputed facts at ... A copy of the request for admission shall be served on all parties entitled to notice. (b)Request for Admission of Genuineness of Document. A party may serve on ...The producing party shall furnish an affidavit stating whether the production is complete in accordance with the request. ... a request to produce documents ... Discovery includes: Asking questions (interrogatories),; Requesting documents (requests to produce),; Asking the other side to admit to something (requests to ... Nov 16, 2020 — Requests for production of documents are requests for the opposing party to make available to the requestor certain documents in its possession. In the case of a request to admit the genuineness of documents, the subject documents must already be in the possession of the requesting party and be attached ... Illinois Supreme Court Rule 216 requires a party served with requests for admission of facts to either (1) admit, (2) deny or set forth reasons why it cannot ... Mar 9, 2011 — (a) Each answer in a response to requests for admission shall be as complete and straightforward as the information reasonably available to the ... Feb 15, 2011 — Request #3: Admit that [name of plaintiff] was harmed while using the [product] in a reasonably foreseeable way. Request #4: Admit that the [ ... HOW TO RESPOND TO REQUESTS FOR PRODUCTION OF DOCUMENTS. • Requests for Production of Documents are a list of documents you must allow the other party or their ...

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Illinois Plaintiff's Request for Production of Documents and Request for Admissions