] RESPONSE NO. ” CCP§ 2033. Responses that only contain objections need not be verified by the party but the response must be signed by the attorney. Requests for admissions are a convenient way for each party to admit or deny Requests for admissions. Louisell, Modern California Discovery §8. Requests for admission can seek an admission which would be dispositive of the entire case and need not be limited to facts, but may seek, when appropriate, opinions of facts or of the application of law to fact. ” RESPONSES WITH ONLY OBJECTIONS Need to bring the motion within 45-days of service of the response. Unfair Extrapolation: “Objection your honor. 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 (b) [1] set forth in the request that relate to statements or opinions of fact or of the application of law Sep 6, 2021 · Overly Broad Discovery Requests. v. During discovery, the Plaintiff (typically the injured party) and the Defendant (the alleged at-fault party) attempt to uncover as much information about the case as possible. The party failing to make the admission had reasonable ground to believe that that party would prevail on the matter. Unlike other forms of written discovery, requests for admission should not be sent out right away. , 246 F. A. Introduction Discovery in civil cases Requesting When propounding requests for admission, be sure to include Form Interrogatory 17. Parties propounding or responding to interrogatories and/or requests for admission can request the propounding party to provide the discovery in electronic format, if the document was originally created in electronic format, which then must be provided to the requesting party within three court days. This testimony is not relevant,” or “Objection, your honor. (a) The party to whom requests for admission have been directed shall respond in writing under oath separately to each request. served by Plaintiff as follows: REQUEST NO. California Civil Discovery Practice KFC 1020 . (c) Each request for admission in a set shall be separately set forth and identified by letter or number. (DISC-020) Tell the other side to admit that a list of facts are true or documents are genuine. Requests for admission apply only to parties to the action. 290 (c). Get form DISC-020. (Wilcox v. , physical evidence in the other party’s possession or control. Interlandi, Monarch Law, Hartford 6:40 p. This is a proper objection in Louisiana state courts, but it is often used improperly or when it is unwarranted. FRCP 36(a). 1, 2024) you may ask each party Current through the 2023 Legislative Session. Ginsberg, 715 S. Drafting Discovery – Types of discovery, when applicable, requests for admission, motions for permission to serve non-standard, and third-party discovery Speaker: Anthony J. 1000. 310(c), and 2033. Telephone: 310. 13-23(a Jan 12, 2010 · Instead of answering, may serve objections. FRCP 36(a)(5). Courtroom: 6 Judge: The Honorable Ronald M. Title this section “Requests for Admission. P. 07 (1963); 2A Barron & Holtzoff, Federal Practice and Procedure §838 (Wright ed. While other discovery devices are meant to obtain proof for use at trial Dec 7, 2022 · Failure to comply with the guidelines in this code affects the outcome of the lawsuit. This article will demonstrate that the correct answer is to “admit” this simple fact and to discuss the reasons why this is true. MOTION TO COMPEL FURTHER RESPONES TO REQUESTS FOR ADMISSION SELARZ LAW CORP. 2d 276 (1969); Chodos v. C. ” Mar 9, 2011 · UPDATED 10/22/2020. You have 30 days to respond to a Requests for Admission. Requests for production can also be used to test, measure, photograph, etc. Birtwhistle (1999) 21 Cal. ) 1 John Doe 2 jdoe@mail. You may object if the request is asking for your analysis, strategy, or thinking about the case. Jan 24, 2022 · Requests for Admission Can Be Very Broad. There was other good reason for the failure to admit. 220, 2031. com . – 6:40 p. If a party to whom requests for admission are directed fails to serve a timely response, the following rules apply: (a) The party to whom the requests for admission are directed waives any objection to the requests, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018. Unless the party Oct 20, 2013 · 3 attorney answers. See CCP §§2030. Each response, if any, is subject to any and all objections as to competence, relevance, materiality Jun 28, 2021 · Requests for admissions. Admissions, answers or objections must be provided to each request. Pursuant to Civil Procedure Rule 198, Defendant responds to the Requests for Admission. These are objections under the California Rules of Evidence. , §§ 2030. Responding and Objecting to Discovery – Document production, working with Each request must be numbered consecutively. 290(c). Zimmer 112 Wis. Monsanto’s responses and objections to plaintiff’s Requests are made solely for the purposes of discovery in this action. 010 . Watkins, a landlord and a lessor. Because the rules and procedures of the discovery process are complex, they can be difficult to interpret and apply correctly. 8681 SELARZ LAW CORP. 030 of the Code of Civil Procedure. Instruction numbers 7, 8 and 10 at the beginning of the RFAs require defendant to respond in excess of its obligations 5 Dec 30, 2012 · Not sure what you mean by boilerplate objections in this instance. Complete the top portion. 040. Copy the name of the Asking Party, Answering Party, and Set Number from the Request for Production. 710 ). Complete the top caption with your name, address, and phone number, the names of the parties in your case, and case number. App. §§ 9-11-26 and 9-11-36 subject to the instructions set forth below: 1. 1416, fns. Subpoena someone or something. Make a list of the items requested. 651. 36 (A). According to the Rule, requests for admission can relate to “statements or opinions of fact or of the appli- Procedure § 2033. California Code of Civil Procedure (CCP) §§ 2031. 1 See, e. , Suite 702 Los Angeles, California 900 49 T: 310. 2d 624, 630, 334 N. Each request for admission shall be full and complete in and of itself. at. Order a witness to appear and bring evidence. Castle’s response that he has no evidence to dispute that Megan Cotton was Lawrence Cotton’s wife tells the Court that Dr. Order a witness to produce business records. 060(a) The first paragraph immediately shall state he identity of the party requesting the admissions, the set number, and the identity Below are sample requests for admission in motor vehicle, medical malpractice, and other tort claims. View DISC-020 Request For Admission form. Order a witness to appear at a deposition. Each of the foregoing objections is hereby incorporated in each and every one of the following responses, whether or not they are specifically identified. Written requests for admission may relate to the following matters: • Statements or opinions of fact • The application of law to fact or opinions thereabout • The genuineness of documents For a full listing of key content covering fundamental civil litigation tasks throughout a federal court litigation lifecycle, see Plaintiff objects to each request to the extent that it is vague, ambiguous, overly broad, unduly burdensome, oppressive, or impossible to answer fully. The true scope of requests for admission is provided in Civ. Code §§ 210, 403. Sep 27, 2021 · A proper objection might include the following language: OBJECTION: This request seeks admission as to matters which are hearsay. 522 (S. Answering Requests for Admissions is very similar to answering interrogatories–you have an obligation to respond in good faith and you have to be careful about your garbage objections. Louisiana’s rules only permit request for admissions regard-ing factual information or the genuineness Responding to defendants’ avoidance tactics in answers to requests for admissions Md. Guide: Civil Procedure Before Trial (TRG 2010), ¶ 8:1288 - 8:1301. The grounds for objecting to a request must be stated. [CCP § 2030. No preface or instruction shall be included with a set of admission requests unless it has been approved under Chapter 17 (commencing with Section 2033. 1 IS TRUE. [Citation. A discovery request can ask what evidence the person knows, but cannot ask what a person thinks the evidence means. 220 [scope and requirements of response]. In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. When a party to a civil case needs to get information from the other side, she can serve the other side with written requests called “discovery requests. 010 for inspection demands). [#] 3 and Request for Order Awarding Monetary Sanctions Against Defendant and Defense 4 Counsel in the Sum Of $1. com An objection to the request was sustained or a response to it was waived under Section 2033. ” Each request should be in a separate paragraph and numbered sequentially. Below is a list of objections to evidence submitted in support of a pleading or motion, such as a motion for summary judgment. Rule 2-434 permits only three possible responses to this request: 1) admit, 2) deny, and 3) Defendant is unable to admit or deny. 1. For each numbered request, write “Response to Request for Admission number” followed by the number of the request. , § 2033. 210 et. – 7:00 p. Requests for admission are often used to clear up administrative issues in a case, including background facts and authenticity of evidence or documents. Response to Requests for Admission A sample filled-in form with instructions is available at the end of this Guide. 1: [ANSWER "ADMITTED" IF THE ENTIRE STATEMENT IN REQUEST. B. 220. See C. Did the responding party provide any response to 17. 1, as it requires the responding party to identify facts, witnesses, and documents which support their denial of any request for admission. , CCP § 2031. 2d 749 (Tex. Feb 15, 2011 · 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. 1 1777 San Vicente Blvd. 1 This [71 Cal. " (Weil & Brown, Civ. 280(c). Elk Run Coal Co. I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. Justia. ). ”. See CCP CCP §§2030. This particular type of objection was critical in the case of White v. When that happens, you Petitioners seek a writ of mandate to compel respondent superior court to set aside its orders of July 25, and November 25, 1968, respectively sustaining objections to petitioners' requests for admissions and denying petitioners' motion for further responses to written interrogatories. ANSWER "DENIED" IF ANY PART OF THE STATEMENT IN REQUEST. The focus of this series is the various issues which cause objections during the discovery process, outlined below: Introduction. Order a witness to appear in court. 210, subd. 1 with respect to the request for admissions, notwithstanding the objections? "Where the question is specific and explicit, an answer that supplies only a portion of the information sought is improper. omitted. So whether the objection is well-founded depends on the exact question in the context of the facts of the case. Generally, interrogatories are objectionable if they seek information not within the scope of discovery defined Created Date: 11/23/2015 12:37:27 PM Requests for admission are written requests sent during the discovery process of a lawsuit. 240 The exception is if the responsive documents have previously been produced in discovery by the responding party. (a) Scope and Procedure. , to plaintiff’s First Requests for Admissions (“Requests”). W. Give notice to a consumer or employee. 210, 2031. 010). Failing to respond to the Request for Admissions: The court will treat your failure to respond to the requests as admission and waiver all your objections. 8685 • F: 310. Whether on a form or not, the request will have a numbered list of facts and/or documents that the opposing side wishes to be admitted as true or genuine. fn. No preface or instruction shall be included with a set of admission requests unless it has been approved by the Court. The cold reality is that most litigators (and even judges) do not understand or truly appreciate the nuances of requests for admission (“RFA”). Apr 20, 2024 · Admissions, Answers or Objections . Permissibility of Discovery Tool. G. Jan 20, 2022 · (c) Each request for admission in a set shall be separately set forth and identified by letter or number. Apr 30, 2021 · This is unacceptable. Sep 30, 2022 · Step 1: Review the General Rules for Requests for Admission. 4th at p. 287555) dselarz@selarzlaw. 3. NO. 210-2033. Just below the top caption identifying the case, the form identifies the Answering (or Oct 8, 2019 · Responding party is not relieved of their obligations because they believe propounding party has the documents. 210. Each objection must be stated separately (no objections to entire set), and must bear the same number or letter as the interrogatory to which it is directed. CCP §2033. 240 - Objections. (a) Each answer in a response to requests for admission shall be as complete and straightforward as the information reasonably available to the responding party permits. 010 and §2030. Plaintiff’s Second Request – Auto Accident. > > Read More. . Make a list in your template. None of the objections or response contained herein is an admission concerning the existence of any documents or materials, the relevance or admissibility of any documents, 2033. If admitted, a fact will not need to be proven at trial, or a document will not need to be authenticated. C35 Oct 9, 2014 · The court can order monetary, issue or evidence sanctions for a party’s failure to respond in good faith to any interrogatory, request for admission or request for production of documents. (d) Each request for admission shall be full and complete in and of itself. Order a witness to appear and bring evidence to court. 310 (c), and 2033. The appropriate objection in this situation would be as follows: Propounding Party’s definition of “you” is impermissibly overbroad and violates the Code of Civil Procedure §2020. ached set of requests for admission. , Inc. 4 (commencing with Section 2018. Requests for admission are governed by Chapter 16 of the Code of Civil Procedure, commencing with section 2033. Interrogatory #1: If your response to Request for Admission #1 was anything but an unqualified admission, state all facts on which you based your response including, without limitation, the name, address and telephone number of all entities who manufactured the widget. Posted in Code Compliant Demand, Responses and Objections. Such requests, which include the sometimes gray area of sorting fact from opinion, are objectionable. Bank of Two Rivers v. Jan 1, 2008 · Request For Admission (DISC-020) Request For Admission. , opinion, hearsay, assumes facts not in evidence A request for admission may properly be used to establish opinions relating to fact or the application of law to fact. the request seeks a legal conclusion. In order to get the information you need, you must make a request using a specific procedure and written format, within a specific timeframe. You have 30 days to respond to the interrogatories. Foote Memorial Hospital d/b/a Henry Ford Allegiance Health ("Allegiance"), by and through its undersigned counsel, and pursuant to Federal Rules of Civil Procedure 26 and 36, provides the following objections and answers in response to Plaintiffs' First Set of Requests for Admissions (the Service of Requests and Time for Responses. Yes, it may be a legitimate objection. C. 1, “a party may serve on another party … written requests that the other party admit the truth of any matter within the scope of discovery, including statements of opinion or of fact or of the application of law to fact…. It complies with Illinois Supreme Court Rule (Supreme Court Rule) 216 and includes common templates of objections and responses. This question is an “unfair extrapolation,” or “This information is beyond the scope of the statement of facts. In form and substance a Rule 36 admission is comparable to an admission in pleadings or a stipulation drafted by counsel for use at trial, rather than to an evidentiary admission of a party. ]” (Gonsalves, supra, 232 Cal. Responses to requests for admission are due within 30 days (5 days in unlawful detainer actions) if the requests were personally served, 35 days if the requests were served by mail, and 30 days plus 2 court days if the requests were served by express mail or facsimile or electronically. If you were served by mail, you typically have 35 days from the date of mailing to respond. 03. 4. Possible objections include, but are not limited to: 1. If a party to whom requests for admission are directed fails to serve a timely response, the following rules apply: (a) The party to whom the requests for admission are directed waives any objection to the requests, including one based on privilege or on the protection for work product under Chapter. —Dallas 1986, writ ref’d n. Defendant’s Objections to the Instructions in the RFAs. Nov 29, 2017 · See also Frontier-Kemper Constructors, Inc. This set of requests for admission will cause the total number of requests propounded to the party to whom they are directed to exceed the number of requests permitted by Section. (Note: if you send more than one set of RFAs to a party, number each request sequentially without repeating the numbers you used on any prior set of RFAs. A. What May Be Requested. 010. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. Please see our separate article on discovery objections here. Evid. com Case 5:05-cv-04188-RMW Document 46 Filed 12/01/2005 Page 2 of 7 1 Mar 1, 2018 · Therefore, the trial court ‘incorrectly concluded that a denial of a request for admission is admissible as a prior inconsistent statement’ to impeach a witness at trial. 2d 230 (1983); see also Schmid v. But written discovery (as opposed to deposition discovery) may inquire about the application of facts to law, because it is written with the assistance of counsel. • Request For Production of Documents (to defendant State Controller), which included 20 requests; • Special Interrogatories (to defendant State Controller), which included 7 interrogatories. 1961). ) a request must answer the request; a statement that the document speaks for itself is not an acceptable response. 010 provides that “Any party may obtain discovery … by a written request that any other party to the action admit the genuineness of specified documents, or the truth of specified matters of fact, opinion relating to fact, or application of law to fact. App. Superior Court, 71 Cal. The template contains practical guidance, drafting notes, and alternate clauses. 710). 010; Weil and Brown, Cal. The admission sought was of no substantial importance. Depending on the request, you may want to state your legal objections to the request and why you cannot admit or deny it. 2d 278] is an appropriate case, under 3) Next, state your requests for admission. Introduction to Discovery – Part 3: Response to Request for Admissions This video was created by Sacramento County Public Law Library’s Civil Self Help Center to assist self-represented litigants in responding to requests for admissions, and may be helpful to prepare your proposed responses. W. 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. Sometimes called “attorney work product,” and this objection applies equally to self-represented litigants. 010, et seq. Lacks Specific Description within Request. 1 IS NOT TRUE. Plaintiff’s First Request – Uninsured Motorist Claim. People respond all the time in this manner to requests for admissions. Title: Response to Request for Admissions California Sample: A Comprehensive Overview Description: In legal proceedings within the state of California, a Response to Request for Admissions serves as a crucial element in the discovery phase. Prac. Summary of Allowable Evidentiary Objections for the California Mock Trial 1. . will be included in the production. Superior Court, 2022 Cal. 300 (c), 2031. The Fourth District Court of Appeal in the case of G olf & Tennis Pro Shop, Inc. (1) Scope. m. Effective: January 1, 2008. 290. Admissions, Answers or Objections . ( Code Civ. Defendants responded to each of the above requests by providing written answers and numerous documents along with certain objections where appropriate. A party must not object solely on the ground that the request presents a genuine issue for trial. GENERAL OBJECTIONS 1. Relevance: “Objection, your honor. 4th 973). DANIEL E. seq require specific statements in your response. ” 2. 2033. § § 2031. Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2033. 1 The Court, having reviewed the moving and opposing papers on Plaintiff’s Motion 2 to Compel Further Responses, Without Objections, to Requests for Admission, Set No. This form is the defendant's response to the plaintiff's request for addmissions in a personal injury action. Whyte 1 Dockets. response to a request for admission is conclusively established against the party making the admission, unless the court permits a withdrawal or amendment of the admission under Code of Civil Procedure section 2033. Work product. Number of Interrogatories. Castle has no good faith basis to deny the request. Unless there is an agreement or a court order providing otherwise, the answering party must respond in writing to requests for admission within 30 days Sep 27, 2021 · One type of request that frequently leads to an objection is one which seeks admission of a matter of opinion. R. Format of supplemental and further discovery (a) Supplemental interrogatories and responses, etc. (Code Civ. Code of Civil Procedure section 2033. (NRCP 33; JCRCP 33) A Practice Note addressing motions specific to responses to requests for admission (RFAs) under Rule 36 of the Federal Rules of Civil Procedure (FRCP). 300. 220 [“. Objections 2024 California Rules of Court. California law places strict limits on the number of discovery requests a party can make. Specifically, this Note addresses a motion to withdraw or amend an admission under FRCP 36(b), a motion to determine the sufficiency of an answer or objection under FRCP 36(a)(6), and a motion for sanctions for failure to admit under FRCP 37(c)(2). (b) Each response shall answer the substance of the requested admission, or set forth an objection to the particular request. (2) An objection to a particular request is without merit or too general. Your response for each request must include either an agreement to comply, a representation of your ability to reply, or an objection to all or part of the request. Gaynier v. §2033. 8. Burke v. Mar 15, 2017 · A Request for Admission (“RFA”) is a discovery device that seems to be gaining popularity. 280. 7. 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) (1) relating to: (A) facts, the application of law to fact, or opinions about either; and. Under Texas Rule of Civil Procedure, 198. 2; CEB California Civil Discovery You use discovery to get information or evidence from the other side in a lawsuit that will help you make your case. Plaintiff objects to each request to the extent that it seeks information that is confidential or which is not relevant to the subject matter involved in the pending action and is not Requests for Admission form does not change existing law relating to requests for admissions, nor does it affect an answering party’s right to assert any privilege or to make any objection. 11777 San Vicente Blvd. CCP § 2033. Jan 6, 2014 · Request for Admission #1: Admit that you manufactured the widget at issue. (1) An answer to a particular request is evasive or incomplete. Plaintiff’s First Request – Auto Accident. Outside the Scope of Discovery. Section 2031. Superior Court, 215 Cal. 010 for requests for admissions and §2031. Attach Documents Only If Relevant to Response. For example, "Objection, The request is vague, ambiguous, uncertain and unintelligible as phrased. Objections . ) The Court of Appeal also noted that Gonsalves found that appellate courts in at least three GENERAL OBJECTIONS: Complainant hereby OBJECTS to the Agency’s Discovery on the grounds that said Discovery is overbroad, vague, overly burdensome, requests irrelevant, immaterial or inadmissible information or information protected by privilege, and/or contains multipart questions in violation of law, rule or regulation. Philip Silberman September 6, 2021. When a request for admission relates to a document, the document should only be attached to the response if it is relevant to the response. , Suite 702 . 230 and 2031. However, the code makes it clear that the requirements in responding to Requests for Admissions are higher. 2. LEXIS 855 answered the question whether the 45-day period to Endnote. Plaintiff’s First Request – Medical Malpractice. D. 010 (amended eff 1/1/17). 13-23. “The court shall make this order, unless it finds that the party to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial compliance with Section 2033. Civ. SELARZ (State Bar No. Overview. May 6, 2019 · We would like to show you a description here but the site won’t allow us. ”] 2 “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and Plaintiff, John Smith, by their attorneys, Jennifer Oquendo and Georgia Trial Attorneys at Kirchen & Grant, LLC, requests that the Defendant, Robert Smith, admit or deny, within 30 days of service of these Admissions, the following statements of law in accordance with O. Objections This template is a set of objections and responses to requests for admission (RFAs) you may use in an Illinois circuit court civil case. 2d 318 (1963). I have previously propounded a total of _______. (a) If only part of an item or category of item in a demand for inspection, copying, testing, or sampling is objectionable, the response shall contain a statement of compliance, or a representation of inability to comply with respect to the remainder of that item or Rule 36 – Requests for Admission. Response To Requests For Admission CODE OF CIVIL PROCEDURE SECTION 2033. As to the “nuts and bolts” of RFA, the statute speaks for Jan 22, 2012 · 4 attorney answers. Lack of Foundation/No Personal Knowledge . e. Absolutely. 010 (§2033. 300 2033. If you are representing yourself in your case, you can consider hiring a lawyer to help (c) Each request for admission in a set shall be separately set forth and identified by letter or number. Los Angeles, California 90049 . Proc. g. 2007) (court awards sanctions against party that objected to request for admission about contents of a relevant document, noting that ‘a favorite excuse for not answering requests for admission in a contract case is that ‘the document speaks TO FIRST SET OF REQUESTS FOR ADMISSION Defendant W. Requests for admissions are not limited to matters within personal knowledge of the responding party, and a responding party Aug 18, 2016 · Alabama Rule of Civil Procedure 36 (a) (a) Request for admission. 300(c), 2031. Misstates the Testimony, Cal. (b) (1) A motion under subdivision (a) shall be accompanied by a meet and confer declaration under Section 2016. Prepare the template for your responses. 36 (a) (3). The title of the form will typically be either special interrogatories or specially prepared interrogatories. Federal Rule 33 (b) (4) emphasizes that the “grounds for objecting to an interrogatory must be stated with specificity. RESPONSES WITH ANSWERS AND OBJECTIONS Need to bring the motion within 45-days of service of the response. 210(a)(3)] Alternative to protective order TIP Don’t object to form (e. Rule 3. These requests might include: Interrogatories, which are written questions about things that are relevant or important to the case. 1: [COPY THE REQUEST FROM THE PLAINTIFF WORD-FOR-WORD. Va. Moral of the Story: You need to bring a motion to strike any “ General Response and Objections ” so the responding party can be held accountable for Dec 1, 2005 · C 05 4188 RMW RS OBJECTIONS TO PLAINTIFFS' REQUEST FOR JUDICIAL NOTICE BY THE GOVERNOR AND ATTORNEY GENERAL; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF Hearing: December 9, 2005 Time: 9:00 a. (1) Admit so much of the matter involved in the request as is true, either as expressed in the request itself or as 6:20 p. 420(b)(1)-(4). P. Conn. Here are some situations that break the codes governing Requests for Admission. Mrs. In each set of supplemental interrogatories, supplemental responses to interrogatories, amended answers to interrogatories, and further responses to interrogatories, inspection demands, and admission requests, the following must appear in the first A request for admission may relate to a matter that is in controversy between the parties. r. 00; and oral argument of counsel having been received by 5 Responses to requests for admission must be signed by the responding party or the party's attorney. Dr. 060. sw ye pt ze fg et hb kl sb dk