Requests to Admit are a fantastic discovery/trial tool, and recent Illinois cases have eliminated a lot of the BS games attorneys used to play with them.
A change to Illinois Supreme Court Rule 216 creates some new requirements though:
1. No more than 30 RTAs can be served without agreement or court approval (including subparts). What’s a subpart? I’d look to Rule 213 and cases discussing interrogatories for guidance. (Why “RTAs” and not “Rs to A”? Sorry grammar police, I’m taking the lead of baseball and it’s constant reference to “RBIs”).
2. The following language must be included in at least 12 point boldface type:
“WARNING: If you fail to serve the response required by Rule 216 within 28
days after you are served with this paper, all the facts set forth in the requests
will be deemed true and all the documents described in the requests will be
Several other recent changes to the Illinois Supreme Court Rules can be found here.