How to Write Requests for Admissions

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Requests for admissions may be used to (1) establish the truth of specified facts, (2) admit a legal conclusion, (3) determine a party’s opinion relating to a fact, (4) settle a matter in controversy, and (5) admit the genuineness of documents. See C.C.P. §2033.010; Weil and Brown, Cal. Prac. Guide: Civil Procedure Before Trial (TRG 2010), ¶¶8:1288 - 8:1301.2; CEB California Civil Discovery Practice 4th Edition §§ 9:17 - 9:20. However that is all good and dandy, but how to write a Request for Admission in order to obtain effective evidence to use for a motion for summary judgment or at trial is difficult.

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