Sample Motion for Withdrawal of Admissions deemed admitted for California
This sample motion for withdrawal of admissions deemed admitted for California is made pursuant to Code of Civil Procedure section 2033.300 and is used when a party wants to ask the Court to withdraw any requests for admission that were deemed admitted against them due to their mistake, inadvertance or excusable neglect. The sample motion has been revised and updated in December 2016 and includes a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.