Illinois Requests to Admit: Rule 216 Response Guide

Legal content overseen by Nathan Walter, Esq., attorney licensed in California (State Bar No. 313299).

Illinois requests to admit require close attention to the response language and the service deadline. Under Illinois Supreme Court Rule 216(c), requested facts and document genuineness are admitted unless the responding party serves the specified sworn statement or written objections within 28 days after service (Rule 216(c)).

For defense teams coordinating client facts and attorney review, this Illinois state-court guide explains sworn responses, request format and the text of the extension rule.

The legal statements below come from the linked Illinois Supreme Court Rules. For general background, see our request-for-admission overview.

How do Illinois requests to admit work under Rule 216?

Illinois Supreme Court Rule 216(a) permits one party to ask another to admit specified relevant facts, and Rule 216(b) permits requests to admit the genuineness of relevant documents (Rule 216(a)–(b)). Rule 216(e) limits an admission’s effect to the pending action and an action commenced under section 13-217 of the Code of Civil Procedure; it does not make the admission usable for any other purpose or in any other proceeding (Rule 216(e)).

In this guide, the requesting party sends the request and the responding party is the party it is directed to. A copy of a paragraph (a) request must be served on all parties entitled to notice (Rule 216(a)).

A request under paragraph (b) concerns the genuineness of “any relevant documents described in the request.” The copies of those documents must be served with the request unless copies have already been furnished (Rule 216(b)). To keep those documents in order, see our guide to organizing discovery documents.

How long do you have to respond to Illinois requests to admit?

Illinois Supreme Court Rule 216(c) sets a period of 28 days after service for serving the specified sworn statement or written objections on the requesting party. Without that response, the requested matters of fact and document genuineness are admitted under the rule. The response, sworn statement of denial or written objection must also be served on all parties entitled to notice (Rule 216(c)).

The rule speaks of serving the response “within 28 days after service thereof,” not filing it. This guide does not calculate a due date; confirm the service date and due date against the rules and any court order in your case.

These provisions are the main rule-text checkpoints for an Illinois Rule 216 review:

The table is a summary, not a deadline calculator or a form. The public-record row applies only to the separate procedure in paragraph (d).

Optionally, a team can record the service information, assign a response owner, collect client facts early and reserve time for attorney review; none of this is a legal requirement. Our discovery response workflow page is general background, not Illinois authority.

Does an Illinois Rule 216 denial have to be sworn, and what if only part is true?

Illinois Supreme Court Rule 216(c)(1) calls for a sworn statement specifically denying the requested matters or setting out in detail why the party cannot truthfully admit or deny them. A denial must fairly meet the substance of the request. When good faith requires a partial denial or a qualification, the response must specify so much of the matter as is true and deny only the remainder (Rule 216(c)).

The rule gives two routes: (c)(1), the sworn statement, and (c)(2), written objections on the ground that some or all of the requested admissions are privileged or irrelevant, or that the request is otherwise improper in whole or in part (Rule 216(c)(2)). The text does not describe every written objection as a sworn statement.

The following example is invented and illustrates the rule’s wording, not a ready-to-serve response. A request asks the defendant to admit that a shipment was delivered on March 3 and inspected that day. The file confirms delivery on March 3, and the defendant confirms that no inspection occurred that day.

Under the “specify so much of it as is true and deny only the remainder” language, the response identifies the delivery fact as true and denies the inspection fact instead of denying the whole request.

The rule text does not prescribe an oath form or who must swear, so confirm those points with the responsible attorney. For general drafting steps, see our discovery drafting process article.

How many Illinois requests to admit are allowed, and what format is required?

Illinois Supreme Court Rule 216(f) limits one party to 30 requests to another party, counting each subpart separately, unless the parties agree to a higher number or the court orders one for good cause shown (Rule 216(f)). Rule 216(g) separately requires a requests-only document with the permitted document attachments, service separate from other documents, and the specified first-page warning in prominent, 12-point-or-larger boldface type (Rule 216(g)).

Paragraph (f) says “If a request has subparts, each subpart counts as a separate request.” As an invented illustration, a request with two lettered subparts counts as two toward the 30.

Rule 216(g) has three requirements for the party serving requests:

1. Prepare a separate document that contains only the requests and the documents required for genuine document requests.
2. Serve that document separate from other documents.
3. Put the following warning in a prominent place on the first page in 12-point or larger boldface type:

WARNING: If you fail to serve the response required by Rule 216 within 28 days after you are served with this document, all the facts set forth in the requests will be deemed true and all the documents described in the requests will be deemed genuine.

The 12-point minimum applies to the served request document itself. Rule 216(f)–(g) does not specify the consequence of a count or format defect (Rule 216(f)–(g)). As an editorial precaution, this guide recommends promptly raising a suspected defect with the responsible attorney rather than ignoring the request; it does not prescribe a remedy.

How do objections and discovery-dispute motions work under Illinois Rule 216?

Illinois Supreme Court Rule 216(c)(2) provides for written objections that requested admissions are privileged, irrelevant or otherwise improper in whole or in part. Rule 216(c) says any objection to a request or to an answer is heard by the court upon prompt notice and motion of the party making the request (Rule 216(c)). Rule 201(k) requires reasonable attempts to resolve discovery differences and a statement in every discovery motion about personal consultation and those attempts, or about opposing counsel’s unavailability or unreasonableness (Rule 201(k)).

On a partial objection, the rule says: “If written objections to a part of the request are made, the remainder of the request shall be answered within the period designated in the request.” The phrase “period designated in the request” differs from the “within 28 days after service” language in the first sentence of paragraph (c). This guide does not resolve how the two phrases interact or add authority to shorten or lengthen the 28-day period (Rule 216(c)).

Rule 201(k) requires every discovery motion to include a statement that counsel responsible for trial of the case, “after personal consultation and reasonable attempts to resolve differences,” have been unable to reach an accord. The alternative is a statement that opposing counsel “made himself or herself unavailable for personal consultation or was unreasonable in attempts to resolve differences” (Rule 201(k)).

What does Illinois Rule 183 allow if a Rule 216 response deadline has passed?

Illinois Supreme Court Rule 183 permits the court, for good cause shown on motion after notice to the opposite party, to extend a rule-based time limit either before or after it expires. The rule says the court “may” extend time. It does not promise an extension or an automatic change in the effect of unanswered Rule 216 requests (Ill. S. Ct. R. 183).

The full operative text of Rule 183 reads: “The court, for good cause shown on motion after notice to the opposite party, may extend the time for filing any pleading or the doing of any act which is required by the rules to be done within a limited period, either before or after the expiration of the time.”

Rule 216(c) still says the requested matters “[are] admitted unless” the specified response is served within 28 days after service (Rule 216(c)). This guide covers only the extension rule’s text. It does not cover case-law standards for relief from deemed admissions, list good-cause factors or predict outcomes. If a deadline is at risk or has passed, the responsible attorney should decide how to proceed.

How are document-genuineness requests different from Rule 216’s public-record procedure?

Illinois Supreme Court Rule 216(b) concerns requests to admit the genuineness of relevant documents and requires copies with the request unless already furnished (Rule 216(b)). Rule 216(d) instead describes a written-notice procedure for public-record copies to be used as evidence. The copy is admissible as admitted facts if otherwise admissible, except to the extent an inaccuracy is identified under oath in an affidavit filed and served within 28 days after service of the notice (Rule 216(d)).

Under paragraph (b), the party asks the other side to admit genuineness, and the response follows paragraph (c). Under paragraph (d), the party intending to use public records may prepare a copy “insofar as they are to be used” and “seasonably” present it to the adverse party by notice in writing.

The paragraph (d) affidavit is made under oath by the adverse party, points out the inaccuracy, and is filed and served within 28 days after service of the notice. This guide does not treat a genuineness admission as an admission of everything a document says (Rule 216(b), (d)).

How can Briefpoint help a defense firm draft responses to requests for admission?

Briefpoint drafts responses and objections to requests for admission, with output editable in Microsoft Word and final review kept with attorneys. Client Bridge sends clients plain-language questions through a secure link so they can answer and upload documents for attorney review.

For defense firms, discovery response drafting produces a Word draft for the attorney to edit and check against what the client provided. Briefpoint also offers Discovery Playbooks.

This guide does not treat software output as proof of Rule 216 compliance. As an optional internal workflow, a defense team can collect the client’s answers, flag unresolved facts for the responsible attorney and compare the editable draft with that information. The attorney keeps final review, including decisions about the response language and the applicable procedural requirements.

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FAQs about Illinois requests to admit: what else should defense teams know?

Illinois requests to admit are governed here by Illinois Supreme Court Rule 216, including its sworn-response language, 30-request limit and first-page warning. The answers below also explain the text of Rule 183 on extensions and preserve Rule 216(e)’s qualification for actions commenced under section 13-217.

Does every Illinois Rule 216 response need to be sworn?

Rule 216(c)(1) specifies a sworn statement for a specific denial or a detailed explanation of why the party cannot truthfully admit or deny. Paragraph (c)(2) separately provides for written objections.

Keep those routes distinct: the quoted rule does not describe every written objection as a sworn statement. It requires service of the specified response within 28 days after service of the request (Rule 216(c)).

Do subparts count toward Illinois’s 30-request limit?

Yes. Illinois Supreme Court Rule 216(f) says each subpart counts as a separate request.

The maximum is 30 requests from one party to another, unless the parties agree to a higher number or the court orders one for good cause shown. The rule’s wording does not describe a fresh limit for each new set (Rule 216(f)).

What warning belongs on Illinois requests to admit?

Rule 216(g) requires the specified warning that failure to serve the required response within 28 days means the stated facts will be deemed true and the described documents deemed genuine. It must appear prominently on the first page in boldface type of at least 12 points. The same subsection separately requires a separate request document and service separate from other documents (Rule 216(g)).

Can an Illinois court extend time after the deadline expires?

Yes. Illinois Supreme Court Rule 183 says the court may extend a rule-based time limit before or after expiration, for good cause shown on motion after notice to the opposite party. That is discretionary language, not a promise of relief.

This answer states the extension rule’s text, not a case-law standard for undoing deemed admissions (Ill. S. Ct. R. 183).

Can a Rule 216 admission be used in another proceeding?

Rule 216(e) limits an admission to the pending action and an action commenced under section 13-217 of the Code of Civil Procedure. It says the admission is not for any other purpose and may not be used against the party in any other proceeding.

A summary saying only “this case” would omit the rule’s express section 13-217 qualification (Rule 216(e)).

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