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Typical number of admissions?

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I am starting discovery requests now, beginning with requests for admissions (RFAs). In reading up, it was reccomended to keep each "question" simple as compound questions are easier to "defeat". I enunciated every conceivable detail of my case and situation, and every permutation of their FDCPA violations, and came up with 311 items in my first set of admissions requests. My first RFA set I'm sending to the Plaintiff debt collector suing me runs to 14 pages! Is this typical or am I maybe overdoing it?

Thanks in advance.

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No it's not typical and yes you're overdoing it.

You're not allowed that many. Check the Code of Civil Procedure

CCP 2033.030: You're allowed only 35 Requests for Admissions that do not relate to the genuineness of documents

CCP 2030.030: You're allowed only 35 interrogatories

And I'm not exactly sure, but the total may be limited to 35 items. Either way, you need to whittle down your list.


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