Sample Motion to Compel Further Answers to Requests for Admission in California

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This sample motion to compel further answers to requests for admission in California is filed pursuant to Code of Civil Procedure section 2033.290 on the grounds that the responses to the requests for admission are not code compliant in that they consist of evasive answers and boilerplate objections.  The sample has been revised and updated in January 2017 and includes the separate statement required by California Rule of Court 3.1345 and is 21 pages, it also includes brief instructions, 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 who has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.