When it's used
Mid-to-late discovery phase to narrow contested issues and set up summary judgment or trial stipulations.
Definition
Requests for Admission are written discovery demands that require the opposing party to admit, deny, or explain why they can neither admit nor deny specific factual propositions, the genuineness of documents, or the application of law to fact. Under California CCP §2033.010 et seq., unanswered or deemed-admitted RFAs become conclusively established facts that cannot be contradicted at trial, making them a powerful tool for eliminating issues from dispute. The paralegal drafts each request as a single, unambiguous proposition—not a compound question—that isolates one fact the opposing party either must own or contest under oath. Strategic use of RFAs can significantly reduce trial complexity by locking opponents into admissions that streamline the presentation of key liability or damages facts.