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If your case is a limited civil case ($25,000 or less) you can request up to a total of 35 combined request for admissions, form interrogatories , special interrogatories, and requests for production.
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.
If an application is made to produce the information under Rule 26(g), the party resisting discovery bears the initial burden to show the court that the information is not, in fact, "reasonably accessible because of undue burden or expense." The requesting party must then show "good cause" why the information should be ...
If the Plaintiff does not respond to your request for admissions within 30 days, then they have admitted each of the statements in your requests. The court considers that the plaintiff admits all the statements are true if they do not deny or object to them.
If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.
California law places strict limits on the number of discovery requests a party can make. In a limited civil case (cases less than $25,000) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of documents.
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. Further, Civ.