If you are like most lawyers, you are using the typical discovery devices to gather up all your information--form interrogatories, special interrogatories, requests for production of documents, and of course the deposition schedule from Hell. However, requests for admissions are rarely in a party’s discovery plan. I suggest you take a closer look at C.C.P. §2033.010 et seq. Requests for admissions are wonderful, tricky little discovery devices that really help you set up your case. Let me explain why.
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