§ 2033.060.Form and content of request for admissions

This section governs the mechanics of drafting a set of requests for admission, not their substance. Sets must be numbered consecutively so the parties and the court can track how many rounds have gone back and forth, and the caption of each set must identify who is requesting the admissions, which numbered set it is, and who must respond. Within a set, each request needs its own letter or number, and every request has to stand on its own, fully answerable without a preface or instructions, unless that preface has been separately approved as part of an official form.

Two restrictions get litigated often. Any term the drafter specially defines within the set must appear capitalized every time it is used, so the responding party always knows a defined meaning is in play. And a request cannot bury multiple admissions inside one, no subparts, and no compound, conjunctive, or disjunctive phrasing, unless approved as an official form. A party requesting an admission that a document is genuine has two additional duties: attach copies of the documents to the requests, and make the originals available for inspection on demand. Finally, this section forbids combining requests for admission with any other discovery method, like interrogatories or a document demand, in a single document.