DISC-020: Requests for Admission in California Injury Cases

DISC-020, Request for Admission, asks another party to admit specified facts or the genuineness of identified documents. Admissions narrow disputed issues in an injury lawsuit. They serve a different purpose from questions seeking a narrative explanation or requests seeking records.

Open the official DISC-020 form and download

Separate factual issues from document authenticity

Draft requests around clearly identified propositions. In a collision case, distinguish the identity of a driver, ownership of a vehicle, and a disputed act of driving. In a premises case, distinguish control of the property from knowledge of a condition. A request about authenticity should identify the exact document and include the material needed to understand it. Admitting a document is genuine does not resolve every dispute about what it proves.

Practical injury-case example

Suppose a photograph shows a floor near the place of a fall. A document-authenticity request concerns whether the photograph is genuine. A separate factual request might concern who controlled the area. Avoid combining those issues into one statement demanding an admission of complete responsibility. Number the requests so a reader readily matches each response to the proposition at issue.

Preparation checklist

  • Identify the responding party and set number.
  • State each requested admission separately.
  • Identify and attach documents used in authenticity requests.
  • Review applicable discovery limits and response requirements.
  • Keep the requests and served responses together.

Common mistake to avoid

Do not ignore a request because it seems unfair or inaccurate. Admissions carry significant procedural consequences. Review timely objections and responses using the actual requests, service record, and applicable rules.

What does Form Interrogatory 17.1 add?

California Courts suggests considering DISC-001 with interrogatory 17.1 when requesting admissions. It seeks supporting information for responses other than unqualified admissions. Review its wording before selecting it.

Related discovery form

DISC-001: Form Interrogatories and follow-up information

Official sources and related guides

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