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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 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 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.
Rule 37 - Failure to Make Disclosures or to Cooperate in Discovery; Sanctions (a) Motion for Order Compelling Disclosure or Discovery (1)Generally. Subject to Rule 26(d), a party may move for an order compelling disclosure or discovery.
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.
For example, Plaintiff may send Defendant a request for admission that states, ?Admit that the front of the vehicle you were operating struck the front of the vehicle the Plaintiff was operating on the date of the car crash.? Both parties may send each other requests for admission.
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.
A party may serve on any other party a written request to admit, for purposes of the pending action only, the truth of any matters within the scope of Rule 26(b) relating to: (A) facts, the application of law to fact, or opinions about either; and (B) the genuineness of any described documents.