Putting the final touches on my response to a lengthy Rule 216 Request to Admit filed by the defendant. In reading some of the recent Illinois cases discussing what constitutes a proper response – came across some helpful information. It is NOT sufficient for responding party to simply claim a lack of knowledge as a reason for a failure to admit or deny. Instead, the answering party must make a reasonable effort to secure answers to Requests to Admit from persons and documents within the responding party’s reasonable control. Requests to Admit continue to represent enormous potholes for the unwary. For additional insight, see Szczeblewski v. Gossett (5th Dist. 2003) 342 Ill.App.3d 344, 277 Ill.Dec. 1, 795 N.E.2d 368