A sample Request for Admissions in California is a numbered set of separately stated, single-fact requests asking the opposing party to admit or deny specific facts, opinions about facts, applications of law to fact, or the genuineness of attached documents. Each request stands alone, targets one fact in plain language, and is drafted to comply with California Code of Civil Procedure Section 2033.060. Below are examples you can adapt, followed by the rules that govern how they must be written, served, and answered.
Sample Fact-Based Requests
Good factual RFAs isolate one fact per request and use concrete dates, dollar amounts, and locations. California’s court self-help materials offer this style of wording:1California Courts Self-Help. Discovery: Request for Admissions
- “Admit that you entered into an agreement with [requesting party] on June 15, 2024.”
- “Admit that under the terms of the agreement, you agreed to pay [requesting party] $500 per month until $5,000 was paid.”
- “Admit that you were exceeding the posted speed limit at the time of the motor vehicle collision on May 12, 2024.”
- “Admit that you were using your cell phone on June 8, 2024, at the time of the collision.”
Notice what these do not do. They do not ask the responding party to admit that they ran a red light and were speeding and were on their phone. Each of those becomes its own separately numbered request.
Sample Document-Genuineness Requests
When you want the other side to authenticate a document, attach the document to the request set as a labeled exhibit and reference it directly:
- “Admit that the document attached as Exhibit A is a true and correct copy of the invoice for repairs made to your vehicle on September 21, 2024.”
- “Admit that the document attached as Exhibit B is a true copy of the handwritten note that you provided to [requesting party] on June 20, 2024.”
Document-authentication requests are not counted against the numerical cap that applies to other RFAs, though a court can limit them if a set becomes burdensome.2Justia. California Code of Civil Procedure 2033.010-2033.080
Formatting the Set
The formatting rules are in CCP 2033.060. Number the requests consecutively. The first paragraph below the caption must identify the party propounding the requests, the set number, and the responding party. Each request must be listed separately with its own number or letter, and each one must be complete on its own. You cannot use a preface or a set of instructions that changes the meaning of the requests that follow.3California Legislative Information. California Code of Civil Procedure 2033.060
For any request about a document’s genuineness, attach the document. The responding party needs to see the exact item you are asking them to authenticate.
One Fact Per Request
CCP 2033.060(f) flatly prohibits requests that contain subparts or that are compound, conjunctive, or disjunctive.3California Legislative Information. California Code of Civil Procedure 2033.060 This is the rule that trips up most self-represented litigants. “Admit that you were driving the vehicle and that you failed to stop at the stop sign” is compound, because it asks the responding party to admit two separate facts at once. If one is true and the other is not, the responding party cannot give a clean answer, and you have handed them a legitimate objection.
Split the request. “Admit that you were driving the vehicle on May 12, 2024” becomes one request. “Admit that you failed to stop at the stop sign at the intersection of Oak and Main” becomes another. Yes, this eats into your numerical limit faster. A clean request is still worth far more than a muddled one that invites an objection you cannot easily overcome.
The 35-Request Limit
Each party is limited to 35 admission requests that do not involve the genuineness of documents. If your first set does not use all 35, the balance carries over to later sets.2Justia. California Code of Civil Procedure 2033.010-2033.080
If your case needs more than 35, attach a Declaration for Additional Discovery to the set. That declaration must explain why the extra requests are justified by the number and complexity of the issues, and it must confirm that you considered whether fewer requests could accomplish the same goal.2Justia. California Code of Civil Procedure 2033.010-2033.080 Boilerplate will not survive challenge. If you find yourself packing multiple facts into one request to stay under 35, that is the signal to file the declaration instead.
What You Can Ask the Other Side to Admit
California’s RFA statute is broader than many litigants realize. Under CCP 2033.010, requests can target facts, opinions relating to fact, applications of law to fact, and the genuineness of documents.4California Legislative Information. California Code of Civil Procedure 2033.010 You are not confined to undisputed background material like dates and addresses. You can ask the other side to admit they breached a contract, that they were negligent, or that a particular legal standard applies to their conduct.
The responding party also has a duty to investigate before answering. They cannot deny a request simply because the answer is outside their personal knowledge without first making a reasonable inquiry into the facts.
Effective drafting starts with your complaint or answer. Walk through each element of every claim and each affirmative defense, then draft requests aimed at the facts supporting those elements. RFAs work best paired with the rest of your discovery: Form Interrogatory 17.1 requires the responding party to explain any denial, which tells you what the other side actually disputes and what evidence they intend to rely on.
When You Can Serve and When Responses Are Due
A defendant can serve RFAs at any point after the lawsuit is filed. A plaintiff must wait until at least 10 days after the summons is served on the responding party, or until that party appears, whichever is earlier. In unlawful detainer actions, the plaintiff’s waiting period drops to five days.5Justia. California Code of Civil Procedure 2033.010-2033.080 Service goes to the responding party and to all other parties who have appeared in the case.
The responding party generally has 30 days after service to respond. In unlawful detainer cases, the deadline shortens to at least five days.6California Legislative Information. California Code of Civil Procedure 2033.250 Either side can ask the court to shorten or extend that period.
Mail service adds calendar days under CCP 1013: five days if both addresses are in California, 10 days if either address is elsewhere in the United States, and 20 days if either address is outside the country.7California Legislative Information. California Code of Civil Procedure 1013 Miscalculating a deadline by even a day can waive objections or trigger deemed admissions.
All discovery, including RFAs, must be completed no later than 30 days before the initial trial date, and motions on discovery disputes must be heard at least 15 days before trial. A continuance does not automatically reopen discovery.8California Legislative Information. California Code of Civil Procedure 2024.020 Work backward from trial when timing your sets, and leave room for follow-up motions.
Why Careful Drafting Pays Off
Two consequences give well-drafted RFAs their weight.
First, if the responding party fails to serve a timely response, the requesting party can move for an order deeming every request admitted. The court must grant that motion unless the responding party serves a compliant proposed response before the hearing. The court has no equitable discretion to deny the motion. Monetary sanctions against the party or attorney whose failure forced the motion are mandatory.9California Legislative Information. California Code of Civil Procedure 2033.280 Once a matter is admitted, it is conclusively established for the rest of the case.
Second, under CCP 2033.420, if a party denies a request and the requesting party later proves that matter at trial, the court can order the denying party to pay the reasonable expenses of making that proof, including attorney fees. The denial does not have to be in bad faith; unreasonable is enough. A denial resting on claimed lack of knowledge can still trigger sanctions if no reasonable investigation was done first.
Those two rules shape drafting strategy. Point your requests at facts you can prove independently through documents or testimony. A carefully drafted request targeting a provable fact puts the other side in a bind: admit and lose the issue, or deny and risk paying for the cost of proof. The sharper the request, the tighter the bind.