Discovery Admission of Fact

I have often had limited success using this form of discovery in personal injury cases. Defendants normally simply deny all requested admissions. There is no penalty in the rules for a denial that ends up being true, other then the potential that I can recover cost incurred in proving a fact denied. However, I came across an idea from a very good blog that sent me to another blog that proposed an interrogatory question to be filed post the admission denials. The author of the blog proposed an interrogatory as follows:
"To the extent that any of your responses to any of Plaintiff's requests for admissions is other than an unqualified admission, list all facts on which you based any part of your response that is not an unqualified admission, identify all documents memorializing each such fact, and identify all persons with knowledge of each such fact."

This is interesting enough to try. After all I like the idea of an admission of fact. But what value when the dog has no bite.

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