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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.
If you do not respond, the other side may ask the judge to order that all the facts are true or documents are genuine. This can often cause you to lose your case.
Common objections to requests for admission include: The request is impermissibly compound. The propounding party may ask you to admit only one fact per statement. You may object to any request that asks you to admit two or more different facts in a single request.
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.
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.
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.
R. 36. Rule 36 - Requests for Admission (A)Availability; procedures for use A party may serve upon any other party a written request for the admission, for purposes of the pending action only, of the truth of any matters within the scope of Civ.