Mississippi Responses - Objections to Requests for Productions of Documents
Description Objections Requests Document
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FAQ
When responding to Requests for Admissions, remember to answer as follows: Admit: If any portion of the Request for Admission is true then you must admit to that portion of the request. You are also allowed to have a hybrid response admit the part of the request that is true while denying another part.
Similar to responses to Requests for Production, responses to Requests for Admissions do not have to be verified. It is critical to respond to Requests for Admissions because failure to respond results in the requests being deemed admitted without the need for a motion to have the responses established as admitted.
If a request asks for a document, make a copy of the document; in your response, describe the document and say that a copy is attached; and attach a copy of the document to the responses you send back to the other side.
SUMMARY: Failure to timely answer discovery or refusal to answer discovery has two important and potentially catastrophic consequences. You may waive your right to object to the discovery even if the other party has no right to the information requested. In other words, you may be forced to give it to them.
Each request must be numbered consecutively. The first paragraph immediately shall state he identity of the party requesting the admissions, the set number, and the identity of the responding party. Each request shall be separately set forth and identified by letter or number. C.C.P.
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.
ANSWER: A fictional document. A non-existent objection neither based in statutory authority nor found in case law. A statement by a party during the discovery phase that they will neither be held to the Code of Civil Procedure nor the rules of evidence.
If you admit the request, write admit for your response. If you deny the request, write deny. If you have to qualify an answer or deny only a part, you must specify the part that is true and deny the rest.
So, can you refuse to answer interrogatories? The answer is, no, you may not. You must answer a Rule 33 interrogatory within 30 days of being served with it. That answer must either permit inspection of the requested information or object to the production of the information for a specific reason.