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You'll need to list the facts that you ask the other side to admit are true, or documents that you ask the other side to admit are genuine. You can use Attachment to Judicial Council Form (form MC-025).
For example, Plaintiff may send Defendant a request for admission that states, ?Admit that the front of the vehicle you were operating struck the front of the vehicle the Plaintiff was operating on the date of the car crash.?
In responding to Requests for Production of documents you have three response choices (1) agree to produce (C.C.P. §2031.220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C.C.P. §2031.230) or (3) object (C.C.P. §2031.240).
Read and answer the questions If the fact that is stated is true, write or check the word ?Admit.? If the fact that is stated is not true, write or check the word ?Deny.?
Proper Objections A responding party has four options: (1) admit; (2) deny; (3) admit in part and deny in part; or (4) explain why the party is unable to answer. It is possible to object to all or part of a request as well, but courts do not like parties who play ?word games? to avoid responding.