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Motion to Have Admissions Deemed Admitted


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Thanks for everyones input on my previous thread on Motion to Compel. I am now stuck on having Admissions Deemed Admitted.

How do I go about this. Is this an entire separate motion or do I include it with the MTC rog's? I am confused and at a stand still.. I cant seem to find any examples in here on how to go about motioning this admissions to be admitted..

any input is always and greatly appreciated!

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I believe that you can include it all in one motion, read your rules to be sure. However I like being a pain in the rear for them and would file two motions and then deliver then together in one stack with your motion to deem admitted on the bottom.

So that would make three motions right? one MTC for prod, MTC interr and one motion to haves admissions deemed admitted.

any examples on the motion for admissions deemed admitted?

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So that would make three motions right? one MTC for prod, MTC interr and one motion to haves admissions deemed admitted.

any examples on the motion for admissions deemed admitted?

We used to be able to get away with combining motions to compel, especially when it made sense to do so (ie doc request asking to produce all docs identified in responses to interrogatories). But the Courts are hurting for money and they will usually require you to bring separate motions so they can get two filing fees.

Motion to deem admitted is pretty simple. You served the RFAs. They did not respond. You sent a letter. They ignored it. Cite a couple of relevant code sections and you are done.

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We used to be able to get away with combining motions to compel, especially when it made sense to do so (ie doc request asking to produce all docs identified in responses to interrogatories). But the Courts are hurting for money and they will usually require you to bring separate motions so they can get two filing fees.

Motion to deem admitted is pretty simple. You served the RFAs. They did not respond. You sent a letter. They ignored it. Cite a couple of relevant code sections and you are done.

Thanks calawyer for all your help. So does this include a notice of motion, the motion, memorandum and declaration?

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