First, do not request anything on Requests for Admissions, anything they failed to answer after 28 days is deemed to be admitted and if they now try to answer them you must object to their answers as being out of time because under Rule 36, if a party fails to answer withint 28 days or more if the time period was specified by the person serving them, then the requests are deemed admitted.
"On (date) we served you with Interrogatories, pursuant to Rule 33 of the Ohio Rules of Civil Procedure
and you have not responded within the 28 days provided by the rule. We are requesting that you provide an answer as required by (set new date, 5-10 days is reasonable) if not we will be forced to file the enclosed motion to compel along with a request for attorney's fees incurred in filing the motion."
As far as the copy of the motion, it is beyond the scope of this service to provide an actual copy, as it may be considered the unauthorized practice of law in Ohio, but it is simply a page with the case heading entitled Motion to Compel Discovery, cite Rule 33 for interrogatories and include the date served on the other party and the date the answers were do. State in the motion that the other party has not answered or otherwise objected. You must also state that you made a bona fide attempt to resolve the matter and attach a copy of the letter requesting the answers and no response was received. You then ask for attorney's fees as the court deems reasonable in addition to any appropriate sanctions as it deems fair.
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