California State Court Requests for Admission

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF [________________________________]

[☐ UNLIMITED ☐ LIMITED] CIVIL JURISDICTION

[REQUESTING PARTY]'S REQUESTS FOR ADMISSION (SET [________]) TO [RESPONDING PARTY]

Requesting Party [FULL NAME] propounds these Requests for Admission, Set [NUMBER], to Responding Party [FULL NAME] in this action.

REQUESTS FOR ADMISSION — MATTERS OF FACT AND APPLICATION OF LAW TO FACT

REQUEST FOR ADMISSION NO. 1: Admit that the incident described in the operative pleading occurred on [__/__/____].

REQUEST FOR ADMISSION NO. 2: Admit that, at the time of the incident described in the operative pleading, Responding Party was [describe role/relationship, e.g., the owner of the vehicle described in the Complaint].

REQUEST FOR ADMISSION NO. 3: Admit that Responding Party [describe conduct alleged, e.g., entered into the written agreement attached as Exhibit A].

REQUEST FOR ADMISSION NO. 4: Admit that Responding Party received the [document/communication] described in Paragraph [____] of the operative pleading.

REQUEST FOR ADMISSION NO. 5: Admit that Responding Party did not [perform the act / make the payment / provide the notice] described in Paragraph [____] of the operative pleading.

REQUEST FOR ADMISSION NO. 6: Admit that the amount of [$____________] remains unpaid under the agreement at issue.

REQUEST FOR ADMISSION NO. 7: Admit that Responding Party owed a duty of [care / performance] to Requesting Party with respect to [________________________________].

REQUEST FOR ADMISSION NO. 8: Admit that Responding Party breached the duty referenced in Request No. 7.

REQUEST FOR ADMISSION NO. 9: Admit that Requesting Party sustained damages as a result of the incident described in the operative pleading.

REQUEST FOR ADMISSION NO. 10: Admit that Responding Party has no documents supporting Responding Party's affirmative defense of [________________________________].

REQUEST FOR ADMISSION NO. 11: Admit that the statement(s) set forth in Paragraph [____] of Responding Party's responsive pleading are not supported by any percipient witness other than Responding Party.

REQUEST FOR ADMISSION NO. 12: Admit that [describe an application of law to fact, e.g., the agreement attached as Exhibit A is an enforceable contract between Responding Party and Requesting Party].

REQUEST FOR ADMISSION NO. 13: [________________________________]

REQUEST FOR ADMISSION NO. 14: [________________________________]

REQUEST FOR ADMISSION NO. 15: [________________________________]

REQUESTS FOR ADMISSION — GENUINENESS OF DOCUMENTS

REQUEST FOR ADMISSION NO. 16: Admit that the document attached hereto as Exhibit [____] ([describe / Bates Nos. ____ through ____]) is genuine.

REQUEST FOR ADMISSION NO. 17: Admit that the document attached hereto as Exhibit [____] is a true and correct copy of the [contract / letter / email / record] dated [__/__/____].

REQUEST FOR ADMISSION NO. 18: Admit that the document attached hereto as Exhibit [____] was [sent / received / executed] by Responding Party on or about [__/__/____].

REQUEST FOR ADMISSION NO. 19: Admit that the signature appearing on the document attached hereto as Exhibit [____] is Responding Party's signature (or the signature of Responding Party's authorized agent).

REQUEST FOR ADMISSION NO. 20: Admit that the document attached hereto as Exhibit [____] is a business record kept by Responding Party in the ordinary course of business.

REQUEST FOR ADMISSION NO. 21: [________________________________]

REQUEST FOR ADMISSION NO. 22: [________________________________]

SIGNATURE

Dated: [__/__/____]

Respectfully submitted,

Signature: [________________________________]
[________________________________], Esq.
State Bar No. [________________________________]
Attorney for [Requesting Party]
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)

(OPTIONAL) DECLARATION FOR ADDITIONAL DISCOVERY

I, [________________________________], declare:

1. I am (☐ a party to this action appearing in propria persona) (☐ presently the attorney for [________________________________], a party to this action).

2. I am propounding to [________________________________] the attached set of requests for admission.

3. 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 2033.030 of the Code of Civil Procedure.

4. I have previously propounded a total of [____] requests for admission to this party.

5. This set of requests for admission contains a total of [____] requests.

6. I am familiar with the issues and the previous discovery conducted by all of the parties in this case.

7. I have personally examined each of the requests in this set of requests for admission.

8. This number of requests for admission is warranted under Section 2033.040 of the Code of Civil Procedure because [state the reasons why the complexity or quantity of issues warrants this number of requests].

9. None of the requests in this set is being propounded for any improper purpose, such as to harass the party, or the attorney for the party, to whom it is directed, or to cause unnecessary delay or needless increase in the cost of litigation.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed on [__/__/____], at [________________________________], California.

Signature: [________________________________]
Attorney for [Requesting Party]

PROOF OF SERVICE

I am over the age of 18 and not a party to this action. I am employed in or a resident of the County of [________________________________], State of California. My business address is [________________________________].

On [__/__/____], I served the foregoing [REQUESTING PARTY]'S REQUESTS FOR ADMISSION (SET [____]) TO [RESPONDING PARTY] on the interested parties in this action by the method indicated below, in accordance with Cal. Code Civ. Proc. §§ 1010–1013 and 1010.6:

☐ By United States Mail — by placing a true copy in a sealed envelope with postage fully prepaid, addressed as shown below, and depositing it with the U.S. Postal Service (Cal. Code Civ. Proc. § 1013(a)).

☐ By Overnight Delivery — by depositing a true copy in a sealed envelope or package designated by the express service carrier, with delivery fees paid, addressed as shown below (Cal. Code Civ. Proc. § 1013(c)).

☐ By Personal Delivery — by personally delivering a true copy to the person(s) at the address(es) shown below (Cal. Code Civ. Proc. § 1011).

☐ By Electronic Service — by transmitting a true copy via electronic service to the electronic address(es) shown below, in accordance with Cal. Code Civ. Proc. § 1010.6 and applicable rules of court.

Served upon:

[________________________________], Esq.
[________________________________] (Firm Name)
[________________________________] (Street Address)
[________________________________] (City, State, ZIP)
[________________________________] (Email)

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed on [__/__/____], at [________________________________], California.

Signature: [________________________________]
Printed Name: [________________________________]

DRAFTING NOTES — OMIT FROM THE SERVED SET

The served requests end with the proof of service above. Remove this section and the sources list below before service. Under Cal. Code Civ. Proc. § 2033.060(d), do not add a preface, definitions, or instructions to an ordinary set of requests. Under subdivision (e), type every specially defined term in all capital letters each time it appears; these sample requests avoid special definitions.

1. California Terminology. Use "Requesting Party" and "Responding Party," consistent with the Civil Discovery Act. The Judicial Council form cover sheet for requests for admission is DISC-020.

2. 30-Day Response Deadline and Deemed Admission. Responses are due within 30 days of service (plus the service-method extension). Cal. Code Civ. Proc. § 2033.250. Failure to respond exposes the Responding Party to a motion to deem the matters admitted and waives objections. Cal. Code Civ. Proc. § 2033.280. This auto-admission consequence is the hallmark of requests for admission.

3. 35-Request Limit. No more than 35 non-document requests may be made as a matter of right (combined across all sets). Cal. Code Civ. Proc. § 2033.030(a). Requests for admission of the genuineness of documents are unlimited. § 2033.030(c). To exceed 35 non-document requests, attach the § 2033.050 Declaration for Additional Discovery.

4. Pair with Form Interrogatory 17.1. Serving Judicial Council Form Interrogatory No. 17.1 concurrently requires the Responding Party to state the facts, witnesses, and documents supporting each response that is not an unqualified admission — building the record for a later § 2033.420 cost-of-proof motion.

5. Cost-of-Proof Sanctions. If a denied matter is later proven, the Requesting Party may recover the reasonable expenses, including attorney's fees, of making that proof. Cal. Code Civ. Proc. § 2033.420. Draft requests that address matters of substantial importance and historical fact to strengthen a later motion.

6. Single Matters Only. Each request must seek admission of a single, discrete matter; compound requests are improper. Cal. Code Civ. Proc. § 2033.060(f). Do not combine requests for admission with other discovery methods in one document. § 2033.060(h).

7. Not Filed With the Court. Requests and responses are served, not filed, except as relevant to a motion (e.g., a motion to deem admitted under § 2033.280 or to compel a further response under § 2033.290). See Cal. R. Ct. 3.250.

SOURCES AND REFERENCES — OMIT FROM THE SERVED SET

• Cal. Code Civ. Proc. § 2017.010 — Scope of Discovery
• Cal. Code Civ. Proc. § 2033.010 — Requests for Admission; Scope (Genuineness of Documents; Truth of Facts, Opinion, Application of Law to Fact)
• Cal. Code Civ. Proc. § 2033.020 — Time to Make Requests
• Cal. Code Civ. Proc. § 2033.030 — 35-Matter Limit (Non-Document Requests); Genuineness of Documents Unlimited
• Cal. Code Civ. Proc. § 2033.040 — Number of Requests; Necessity for Additional Discovery
• Cal. Code Civ. Proc. § 2033.050 — Declaration for Additional Discovery (Form)
• Cal. Code Civ. Proc. § 2033.060 — Form and Content of Requests; Single Matters; No Combination With Other Discovery
• Cal. Code Civ. Proc. § 2033.070 — Service of Requests
• Cal. Code Civ. Proc. §§ 2033.210–2033.240 — Form and Content of Response; Reasonable Inquiry; Objections
• Cal. Code Civ. Proc. § 2033.250 — 30-Day Response Deadline (5 Days in Unlawful Detainer)
• Cal. Code Civ. Proc. § 2033.280 — Failure to Respond; Waiver of Objections; Matters Deemed Admitted; Sanctions
• Cal. Code Civ. Proc. § 2033.290 — Motion to Compel Further Response
• Cal. Code Civ. Proc. § 2033.300 — Withdrawal or Amendment of Admission
• Cal. Code Civ. Proc. § 2033.410 — Effect of Admission; Conclusively Established
• Cal. Code Civ. Proc. § 2033.420 — Cost-of-Proof Sanctions for Failure to Admit
• Cal. Code Civ. Proc. §§ 1010–1013, 1010.6 — Service of Papers
• Cal. Evid. Code § 250 — Definition of "Writing"
• Judicial Council Form DISC-020 — Requests for Admission (Cover Sheet)
• Judicial Council Form Interrogatory No. 17.1 — Facts Supporting Non-Admissions
• California Courts (Forms): https://www.courts.ca.gov
• California Legislative Information (Codes): https://leginfo.legislature.ca.gov

This template is designed for use in the California Superior Court. Verify all Code of Civil Procedure citations, confirm any applicable local rules and standing orders, attach copies of any documents whose genuineness is requested, count non-document requests against the 35-request limit, and tailor each request to the specific claims and defenses at issue. Have the document reviewed by a licensed California attorney before service.