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CR 45.04 Protection of a person subject to a subpoena If objection is made, the party serving the subpoena shall not be entitled to inspect and copy the materials except pursuant to an order of the court from which the subpoena was issued. The party serving discovery may, upon notice, move for an appropriate order.
Each party may propound a maximum of thirty (30) interrogatories and thirty (30) requests for admission to each other party. For purposes of this section, each subpart of an interrogatory or request shall be counted as a separate interrogatory or request.
Unless your written response includes only objections without any factual assertions, it must be verified. This means it must include a statement under the penalty of perjury that your response is true and correct. (CCP § 2031.250). Failure to include this verification has the same effect as not responding at all.
Rule 36.01 - Request for admission (1) A party may serve upon any other party a written request for the admission, for purposes of the pending action only, of the truth of any matters within the scope of Rule 26.02 set forth in the request that relate to statements or opinions of fact or of the application of law to ...
If all of the RFPs are not produced based solely on legal objections, the requests for production do not need to be verified.
Rule 36.01 - Request for admission (1) A party may serve upon any other party a written request for the admission, for purposes of the pending action only, of the truth of any matters within the scope of Rule 26.02 set forth in the request that relate to statements or opinions of fact or of the application of law to ...
Also, Federal Rules of Civil Procedure have placed 25 questions per party limitations on the use of interrogatories, but there is no numerical limit in FRCP on the requests for admission (unless specified differently in Local Rules of the state, which most states do have).
Requests for admission are used to ask another party to admit that certain facts are true, or that certain documents are authentic. If admitted as true or authentic, these facts and documents do not need to be proven or authenticated at trial.
Proper Objections A responding party has four options: (1) admit; (2) deny; (3) admit in part and deny in part; or (4) explain why the party is unable to answer. It is possible to object to all or part of a request as well, but courts do not like parties who play ?word games? to avoid responding.
Here are the most common objections to RFAs. Privilege. An objection based on privilege must clearly state the particular privilege invoked and may indicate the basis for its applicability. ... Work Product. ... Request exceeds numerical limit. ... Burdensome and oppressive. ... Relevance.