§ 2033.050.Requesting more than 35 admissions;

This section supplies the exact language a party must use to invoke Section 2033.040's ground for exceeding the 35-request cap. Rather than leaving the required showing to each attorney's own wording, the statute sets out a model declaration nearly word for word, signed under penalty of perjury by the party or the attorney requesting the admissions, and attached to every set that pushes the running total past 35.

The declaration has to do real work, not recite boilerplate. It must identify how many requests for admission have already gone to this particular responding party, state how many the current set adds, confirm that the declarant is familiar with the issues and the discovery already conducted in the case, and has personally examined each request in the set, and then explain why the complexity or the quantity of issues in this particular lawsuit warrants the number requested, tied to the facts of the case rather than the statutory language alone. It closes with an assurance that no request is being propounded for an improper purpose such as harassment or needless delay.