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4) Although there are no limits on how many requests you can include in an RFA they must pertain to the claims or defenses in your lawsuit. Consider limiting the content of your RFAs to: ? Whether a fact is true or false.
The court shall make the requested order for deemed admissions, unless it finds that before the hearing on the motion the party to whom the requests for admission have been directed has served a proposed response to the requests for admission that is in substantial compliance with CCP §§ 2033.210-2033.230. (Code Civ.
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.
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.
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.
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.?