Q: How do I properly object to a RTA?

A: There is no need to object; simply respond "yes" or "no". Remember, if you fail to respond in a timely manner, the request for admission will be deemed to be admitted.

A: You are playing with fire by not hiring an attorney or at least setting an appointment to consult an attorney on this particular issue. The purpose of a Request for Admissions is for the other side to seek AN AWARD OF ATTORNEY's FEES, triggered if they win at trial and prove at trial a fact that you deny in your responses to the Request for Admissions. Even if your side is the "right" side of this dispute, there is always a risk of losing at trial.

If you're going to represent yourself, you need to fully read and understand the Fla. Rules of Civil Procedure, including the rule on requests for admissions. You can easily find the rules on line by googling, then see the table of contents to find the rule applicable to the issue at hand. An attorney can advise you on everything you need to know about the rule, including what is objectionable, and how to state an objection.

The particular request you mentioned may not be objectionable (in which case you can state "denied" or "admitted") - but a RELIABLE legal opinion on that cannot be obtained by an on-line inquiry. Also, even if that particular one is not objectionable, there may be other requests in that set that are (in which case you would state an objection rather than admission or denial).

A: This might be too late for your particular case, but there are limited objections that you can make to a request for admissions under Rule 1.370. Two of which include the following (NOTE, you should nevertheless answer the request):

1. Although this admission is responded to, it is objectionable insofar as it seeks an admission concerning a central issue in the case. Consequently, the denial of this admission cannot be a basis for awarding attorney’s fees should the trial in this case prove the facts sought by this admission. Arena Parking Inc v. Lon Worth Crow Ins. Agency, 768 So. 2d 1107, 1113 (Fla. 3d DCA 2000) (“expenses incurred by a successful litigant as a result of the opposing party's failure to admit requests for admissions may not be assessed against the opposing party for denying a request to admit a hotly-contested, central issue to the case”); Shaw v. State, 616 So.2d 1094 (Fla. 4th DCA 1993) (affirming a denial of attorneys’ fees after a non-jury trial in which the defendants prevailed after having made a request for admission on the central issue in the case, which the plaintiff refused to admit).

2. Objection, calls for a legal conclusion. Rule 1.370 does not permit requests seeking legal conclusions. Fla. R. Civ. P. 1.370 (committee note observing that the revised rule “continues to make no provision for requests seeking a purely legal conclusion”). More specifically, this admission seeking ___ [fill in the specific issue in the RFA] ___ is a legal question. Therefore, it not a proper subject for a request for admission. PennyMac Corp. v. Labeau, 180 So.3d 1216, 1220 (Fla. 3d DCA 2015); Davis v. Dollar Rent A Car Sys., Inc., 909 So. 2d 297 (Fla. 5th DCA 2004) (rev'd on other grounds, Williams v. Davis, 974 So. 2d 1052 (Fla. 2007)) (holding that requests for admissions seeking purely legal conclusions are inappropriate, and the failure to respond to such a request may not be the basis for a summary judgment.