Sample Motion to Have Matters Deemed Admitted for California

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This sample motion to have matters deemed admitted for California is used when a party has served requests for admission on the other party, who has failed to respond. The motion is made pursuant to section 2033.280 of the Code of Civil Procedure and requests that the Court make an order establishing admissions as to the truth of each matter specified in the requests for admission. The motion 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 the sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.