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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.
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.
Each discrete subpart of an interrogatory is considered a separate interrogatory. (3) Requests for admissions. Each party may serve no more than 25 requests for admissions. Requests for admissions may be used only to address jurisdictional facts or the genuineness of any documents served with the request.
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.
Raise this objection if the request requires you to do legal analysis and requests a legal opinion. For example, a Request for Admissions that asks you to admit that your defenses lack merit. You may object if the request is asking for your analysis, strategy, or thinking about the case.
Unless the responding party states an objection or asserts a privilege, the responding party must specifically admit or deny the request or explain in detail the reasons that the responding party cannot admit or deny the request. A response must fairly meet the substance of the request.
The number of requests for admissions for each party is limited to thirty. No further requests for admission will be served unless authorized by the court.
Relevancy is a common objection to social media discovery. While defense counsel can freely access publicly available content, some courts require a showing of relevancy before allowing access to social media pages with higher privacy settings.