🤯 Discovery Drama! Dodging the Bullet: How to Properly Object to Requests for Admission in a California Lawsuit 📜
Let's face it, getting hit with a set of Requests for Admission (RFAs) in your California lawsuit feels like your opponent is playing a round of "Gotcha!" They're basically firing off a list of statements and daring you to say "No, that's not true" without getting totally burned later. It's a key part of the whole discovery rodeo, designed to narrow down the issues for trial. But hey, you're not going to just roll over and admit everything, are you? Absolutely not! This is where you put on your legal armor, grab your objection shield, and get ready to fight for your facts.
Responding to RFAs in the Golden State isn't just about yelling "Deny!" at the top of your lungs. That's a rookie move that can cost you a pretty penny (we’re talking sanctions, folks!). You need to be smart, specific, and follow the rules to a T, or you might find those pesky facts are deemed admitted—and that's a whole lotta nope you want to avoid.
Step 1: Getting Your Head in the Game and Meeting the Deadline 🗓️
First things first, you gotta treat this like the serious business it is. RFAs are no joke. An admission is generally treated as conclusive proof at trial, meaning you can't come back later and try to argue the opposite. That's a permanent decision, my friend.
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| Can You Object To Requests For Admission California |
1.1. Know Your Clock ⏰
In California civil court, you typically have 30 days after service to respond to the RFAs (if you were served by mail, tack on an extra five days!). Don't miss this deadline! Missing it is like handing your opponent a free win—they can file a motion to have all those requests deemed admitted, and then you've got a seriously uphill battle. You'll be sweating bullets trying to get the court to grant you relief from a waiver.
1.2. The Format of the Fight 📝
Your response has to be a verified response—meaning you sign it under oath, like swearing on a stack of pancakes that it's all true. You'll need to use pleading paper (the stuff with numbers down the side), and your response must:
Identify the responding party (that's you!) and the requesting party.
State the set number of the requests (e.g., "Set One").
Address each request separately, bearing the same identifying number as the request you're responding to.
Must be served on the requesting party (and all other parties who have appeared) by the deadline.
QuickTip: A careful read saves time later.
Step 2: The Three Basic Responses (And When to Use 'Em) 🛑
For every single RFA, you have one of three primary options: Admit, Deny, or Object. Let’s break down the plays.
2.1. The "Admit" Card 💯
If the statement is 100% true and you know it, you gotta ADMIT it. It's just the right thing to do. You can't deny something you know is factual just to be a pain. If you get caught playing games and improperly denying something that's proven true at trial, the court can make you pay for the costs (including attorney fees) that the other side incurred proving that fact. Ouch.
2.2. The "Deny" Card (But Be Specific!) 🙅
If the statement is not true, you DENY it. If only part of the statement is untrue, you must ADMIT the part that is true and DENY the part that is false. This is called a qualified admission/denial. You must be super clear about which part you are admitting and which part you are denying. A blanket denial when part is true is a fast track to sanctions.
2.3. The "Lack of Information" Card (The Reasonable Inquiry) 🤔
If you genuinely can't admit or deny the request, you can state that you lack sufficient information or knowledge to admit or deny the matter. But wait, there's a catch! You must also state that you have made a reasonable inquiry into the matter and that the information known or readily obtainable is insufficient to enable you to admit or deny. You can’t just shrug your shoulders and say "I dunno." You have to actually look for the info!
Tip: Don’t just scroll to the end — the middle counts too.
Step 3: Deploying Objections—Your Discovery Shield! 🛡️
Now for the main event! This is where you object to the request instead of admitting or denying it. Remember, if you make an objection, you must set forth the specific ground for the objection clearly in your response. Boilerplate, general objections are a major fail and often seen as a waiver by the judge.
3.1. Privilege Objections (The Confidentiality Cloak) 🤫
This is when the information being requested is legally protected from disclosure. These are rock-solid objections if they apply.
Attorney-Client Privilege: Halt! This protects confidential communications between you and your lawyer. You can object if admitting or denying would require you to disclose something you talked about with your attorney.
Work Product Doctrine: This protects your lawyer's thoughts, impressions, conclusions, and legal theories prepared in anticipation of litigation. If the RFA asks for an admission that would reveal your case strategy, this is your go-to.
Other Privileges: Think doctor-patient, priest-penitent, etc., if they are relevant to the admission requested.
3.2. Form and Rule Objections (The Technical Knockout) 🥊
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These are objections that target the way the request is written, not the substance of the information.
Impermissibly Compound or Disjunctive: Bingo! California law says each RFA must contain only a single statement or fact. If they've jammed two or more facts into one request (e.g., "Admit you were driving and the light was red"), you can object because it's compound. You can't just admit the red light part and deny the driving part if they are lumped together.
Vague, Ambiguous, or Unintelligible: If the request is so poorly worded that you can’t possibly figure out what they want you to admit (e.g., "Admit you were there"), you can object. You can’t admit or deny if you don't speak their mystery language.
Calls for a Legal Conclusion/Contention: While RFAs can sometimes ask for an admission on a matter of opinion or legal conclusion, if the request asks you to admit something that is purely a legal conclusion without any underlying facts (e.g., "Admit your complaint lacks merit"), you might successfully object. This is a bit of a gray area, so use it wisely!
Exceeds Numerical Limit: Check the count! A party can only request, as a matter of right, 35 matters that don't relate to the genuineness of documents. If they've gone over the limit without the proper declaration for additional discovery, object to the ones over the 35 mark!
3.3. Burden and Scope Objections (The Overkill Defense) 🤯
This is for when the request is just too much, man.
Unduly Burdensome or Oppressive: If responding to the request would require an unreasonable and unfair amount of work, expense, or time (especially compared to what the case is actually about), you can object. You'd need to explain why it's unduly burdensome—just saying "it's hard" isn't enough.
Not Relevant to the Subject Matter: Discovery must be relevant to the subject matter involved in the pending action. If they're asking about the color of your socks in a car accident case, and the sock color has zero bearing on the crash, you can hit them with a relevance objection. Seriously, what is up with the socks?
Tip: Reread slowly for better memory.
Step 4: What Happens Next? (The Post-Objection Phase) 📬
Once you've sent your killer response, the ball is back in their court. They have a few options, and you need to be ready for the follow-up.
4.1. The "Motion to Compel Further Response" Threat 😲
If the propounding party thinks your objection is bogus (without merit or too general) or that your denial is evasive or incomplete, they can file a Motion to Compel Further Response. This is where the judge gets involved. If the judge agrees with your opponent, they'll order you to answer, and you might even get sanctioned (fined) for forcing the issue. This is why specific and good-faith objections are absolutely key! You have to show you acted with substantial justification.
4.2. The "Meet and Confer" Requirement (Adulting Time) 🤝
Before the propounding party can even file a motion to compel, they must meet and confer with you. This means they have to try, in good faith, to resolve the discovery dispute with you informally first. They'll probably send you a "meet and confer" letter outlining why they think your objection stinks and demanding a better answer. It's like getting called to the principal's office, but with way more paperwork.
Pro-Tip: Always document your meet and confer efforts. Be polite, be professional, and be prepared to back up your objections with the actual California Code of Civil Procedure (CCP) rules!
FAQ Questions and Answers
QuickTip: Pause at lists — they often summarize.
How to Write a Response to Requests for Admission in California?
You must prepare a formal, written response on pleading paper that is served under oath (verified). Address each request separately by its number and state one of the following: Admit, Deny, state that you lack information (after a reasonable inquiry), or state a specific objection with a clear ground (citing the CCP is a power move!).
What is the Deadline to Respond to Requests for Admission in California?
The general deadline is 30 days after the date of service, plus any extra days if served by mail (usually five business days) or by other methods as specified in the California Code of Civil Procedure. Missing this deadline is dangerous and can lead to the requests being deemed admitted.
How Do I Object to a Compound Request for Admission?
You object by stating that the request is "impermissibly compound" because it seeks the admission of more than one single fact or statement in a single numbered request, which is prohibited by California Code of Civil Procedure .
What is a "Reasonable Inquiry" When Denying an RFA for Lack of Knowledge?
A "reasonable inquiry" means you have made a good-faith, diligent effort to obtain the information, including reviewing all documents and speaking to all persons reasonably available to you. You must explicitly state in your response that a reasonable inquiry has been made but was insufficient to allow you to admit or deny.
Can I Get Sanctioned for Improperly Objecting to an RFA?
Yes, you sure can. If the court finds your objection to be without merit or too general, and the propounding party successfully brings a motion to compel further response, the court must impose a monetary sanction (like attorney's fees) against the party or attorney who unsuccessfully opposed the motion, unless they had substantial justification. Keep your objections legit!
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