Motion to Compel: Requests for Admission

You are the Plaintiff’s lawyer. You are bent on getting your case ready for trial from the moment you file a lawsuit. After you have almost completed discovery, you send out requests for admission to truly narrow the issues you will face at trial. Good job. You are more thorough than probably 99% of Maryland personal injury lawyers.

But ninety-nine percent of the time, you will get obstructionist answers to your requests for admission. Even good, reasonable defense lawyers file woefully inadequate responses. Two reasons for this: (1) No one wants to admit anything before trial (including, ironically, the things they have already admitted); and (2) there is little chance anyone will hold their feet to the fire.

The reason for the latter is simple: it is painfully tedious to file a motion to compel evasive answers so most personal injury lawyers don’t.

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