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The conventions for addressing opposing counsel may vary by jurisdiction and court rules, but here are some common practices and guidelines: Use of Titles and Last Names: Lawyers often address each other by their last names and may include a professional title, such as "Mr. Smith" or "Ms.
Stay alert and answer truthfully without being swayed by the opposing counsel's suggestions. Stick to the facts and provide your own perspective when necessary. These questions involve hypothetical scenarios that may or may not reflect reality. Approach them cautiously and seek clarification if needed.
Dear [Opposing Counsel Name], I am writing to follow up on our recent communication regarding [case name]. I have not yet received a response from you regarding [list the specific issue or question]. Please let me know your thoughts as soon as possible so that we can continue to move forward with the case.
Common objections to requests for admission include: The request is impermissibly compound. The propounding party may ask you to admit only one fact per statement. You may object to any request that asks you to admit two or more different facts in a single request.
Many lawyers reply to RFAs with objections: seeks an expert opinion, calls for legal conclusion, we don't have enough information to admit nor deny to this admission at this point, etc.