6 Grounds for Objecting to Requests for Admission

A party may respond to an individual request for admission (RFA) by objecting to all or part of it. CCP §2033.230. The right to object is waived if not stated in a timely response, so it’s important to consider objections carefully. Here are the most common objections to RFAs. 1. Privilege. An objection based on privilege must clearly state the particular privilege invoked and may indicate the basis for its applicability. CCP §2033.230(b). “Privilege” in CCP §2033.230(b) appears to refer to the same evidentiary privileges that can be raised to block disclosure at trial. For example: Objection: Lawyer-client privilege. Admitting or denying this request would require me to disclose the content of a conversation with my former attorney. or Objection: Request No. 9 calls for disclosure of a confidential marital communication. 2. Work Product. An objection to an individual RFA may expressly assert that the matter on which the admission is…

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