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Requests for
admission of facts and genuineness of documents are, obviously, case-specific; these are
examples from a number of different cases, child abuse, property disputes, custody and
visitation, and other things. (Formatted for red line paper.)
____________________, * IN THE
____________________, *
* * * * * * * * * * *
INSTRUCTIONS
A. Pursuant to Rule 2-424, you are requested to file a full and complete written response to
each of the following admissions. If you do not respond within 30 days after this request
has been served upon you, each matter of which an admission is requested shall be deemed
admitted. You or your attorney must sign your response to the following admissions and
serve your response upon counsel for the Defendant at the above address.
Request for Admission of Facts & Genuineness of Documents Plaintiff vs. Defendant
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B. As to each matter of which an admission is requested, the response shall specify an
objection, or shall admit or deny the matter, or shall set forth in detail the reason why the
respondent cannot truthfully admit or deny it. The reasons for any objection shall be stated.
C. A denial shall fairly meet the substance of the requested admission, and when good faith
required that a party qualify an 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 deny or qualify the
remainder.
D. A respondent may not give lack of information or knowledge as a reason for failure to admit
or deny unless the respondent states that after reasonable inquiry the information known or
deny.
E. A party who considers that a matter of which is an admission is requested presents a genuine
issue for trial may not, on that ground alone, object to the request but the party may, subject
to the provisions of Maryland Rule 2-424(e), deny the matter or set forth reasons for not
F. Any matter admitted under this Rule is conclusively established unless the Court on motion
1. The document attached as Exhibit A is a Safety Plan dated March 24, 2011, from the
Request for Admission of Facts & Genuineness of Documents Plaintiff vs. Defendant
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2. You and your sister, [sister’s name], were investigated by the Worcester County
Department of Social Services for being verbally and physically abusive to your son,
[child’s name].
3. The child alleged that you pushed his head down to the ground and that you refer to you
4. The child alleged that [sister’s name] locked him in a closet, shot him with a bee-bee gun,
5. The Safety Plan issued by the Worcester County Department on March 24, 2011, states
that, “[child’s name] should not visit with his father, [father’s name], and his aunt,
[sister’s name], until further notice from Worcester County Department of Social
Services.”
6. The Safety Plan lists no specific date for re-evaluation and states only “to be
determined.”
7. The deed attached as Exhibit A is the deed by which [name] acquired [property].
8. The “fence . . . which extends over the property line between [next door property] and
[requests from a visitation case in which a military parent absconded with the child]
10. Defendant did not deploy to Iraq with the rest of Defendant’s company.
11. Defendant was listed Absent Without Leave (“AWOL”) from August 21, 2007 until
Request for Admission of Facts & Genuineness of Documents Plaintiff vs. Defendant
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12. That Defendant received non-judicial punishment for being AWOL on November 8,
2007.
14. Defendant has not been in contact with his commanding officer since November 27,
2007.
15. Plaintiff has been denied visitation with the minor child [name] since December 10, 2007
17. During the February 3, 2008 phone call, Defendant again denied visitation to the
Plaintiff.
18. Defendant was not summoned to Fort Drum on June 19, 2008, the date of the scheduling
19. Defendant did not appear of his own volition at Fort Drum on June 19, 2008.
20. That you do not own the property located at [party’s home].
21. That the only people who live at [party’s home] are you, [friend] and [child].
22. That you have not had a job since prior to August 1, 2011.
24. That prior to June 2011, [child] never lived with you.
26. That you have no photos of bruises on [child] that you believe were caused by Defendant.
27. That Defendant never agreed that you could become [child’s] representative payee for his
Request for Admission of Facts & Genuineness of Documents Plaintiff vs. Defendant
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28. That you never notified Defendant you were placing [child] in therapy.
35. That in that application for food stamp benefit, you indicated that you were homeless.
36. That you have a pending charge for possession of paraphernalia in Montgomery County,
37. That you are currently on probation for the assault conviction.
38. That you have a pending court hearing for a probation violation in Montgomery County.
39. That you have denied Plaintiff access to [child] since September 16, 2014.
41. That you were convicted of Assault in the 2nd degree against Plaintiff in June, 2011.
42. That as a result of that conviction, you were sentenced to three years prison time in the
Respectfully submitted,
Attorney
Firm
Address
Phone
Email
Request for Admission of Facts & Genuineness of Documents Plaintiff vs. Defendant
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Certificate of Service
Attorney
Request for Admission of Facts & Genuineness of Documents Plaintiff vs. Defendant
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