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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.
Responses to Requests for Admissions The party to whom requests for admissions have been directed must respond separately to each item by admitting the truth of the statement, by denying the item, or by explaining why it cannot specifically admit or deny the item.
The circumstances are rare in which a Party can avoid answering a Request for Admission. Unlike an Interrogatory where you can object and not answer, there are serious consequences for not admitting or denying an answer without a valid objection or privilege. An objection requires a legal objection such as: Hearsay.
Responding to a Request to Admit Admit: the responding party may admit that a fact is true or that a document is authentic. ... Deny: the responding party may deny the truth of a fact or the authenticity of a document. ... Refuse: the responding party may refuse to admit the truth of a fact or the authenticity of a document.
If the fact that is stated is not true, write or check the word ?Deny.? If you are not able to determine if it is true, write or check ?Answering party lacks information and belief sufficient to determine the truth or falsity of the request despite a reasonable inquiry into the matter and therefore denies.?
A party who considers that a matter of which an admission has been requested presents a genuine issue for trial may not, on that ground alone, object to the request; the party may, subject to the provisions of Rule 37(c), deny the matter or set forth reasons why the party cannot admit or deny it.
If you do not, the requesting party may file a motion to have the facts deemed admitted by the court, or a motion to compel further responses, both of which may carry sanctions (monetary penalties) against you.