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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).
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.
A Request for Admission asks the other side in your case to admit that a fact is true or that a document is authentic. If the other side admits that something is true or authentic, you will not need to prove that at trial.
(a) A defendant may make requests for admission by a party without leave of court at any time. (b) A plaintiff may make requests for admission by a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first.
WHAT IS A MOTION TO DEEM FACTS ADMITTED? A motion to deem facts admitted is a request made by a party to the court to treat certain facts as admitted because the other party failed to respond to a request for admission within the time allowed by the rules of civil procedure.
Requests for admission are generally used toward the end of the discovery process to settle uncontested issues and simplify the trial.
Requests for admissions may be used to (1) establish the truth of specified facts, (2) admit a legal conclusion, (3) determine a party's opinion relating to a fact, (4) settle a matter in controversy, and (5) admit the genuineness of documents.
Rule 36(a)(1) limits the types of requests to be limited to (A) facts, the application of law to fact, or opinions about either; and (B) the genuineness of any described documents. However, the rule places no limits on the number of requests which may be made of either litigant.