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Requests for admission are used to ask another party to admit that certain facts are true, or that certain documents are authentic. If admitted as true or authentic, these facts and documents do not need to be proven or authenticated at trial.
Unless your written response includes only objections without any factual assertions, it must be verified. This means it must include a statement under the penalty of perjury that your response is true and correct. (CCP § 2031.250). Failure to include this verification has the same effect as not responding at all.
In a civil action, a request for admission is a discovery device that allows one party to request that another party admit or deny the truth of a statement under oath. If admitted, the statement is considered to be true for all purposes of the current trial.
Here are the most common objections to RFAs. Privilege. An objection based on privilege must clearly state the particular privilege invoked and may indicate the basis for its applicability. ... Work Product. ... Request exceeds numerical limit. ... Burdensome and oppressive. ... Relevance.
Have your client verify the interrogatories. Federal Rule of Civil Procedure 33(b)(5) requires the attorney to sign the objections and the client to sign the answers.
If all of the RFPs are not produced based solely on legal objections, the requests for production do not need to be verified.
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 matter is admitted unless, within 30 days after being served, the party to whom the request is directed serves on the requesting party a written answer or objection addressed to the matter and signed by the party or its attorney.