Requests for Admission
Of all of the written discovery Requests for Admission are the trickiest to use effectively, but if done properly can eliminate several issues from your case.
Requests for Admission are essentially a set of true/false questions but asked as admit or deny. So if a statement is true you state “admit” and if the statement is not true you state “deny”. Keep in mind that anything admitted is no longer at issue so you have to be careful of only admitting to statements are entirely true. The Code of Civil procedure allows for the situation in which only part of a statement is true. If that is the case, then you must admit as much as possible.
Further, if you do not know whether the statement is true or not you may answer by standing that you lack sufficient information or knowledge to answer the Request for Admission.
Now, what makes the Request for Admission so potent, is that if a matter is denied but at trial proven to be true, the party that proved the matter can receive the costs of having to prove the truth of a denied Request for Admission. This puts teeth behind answering the Requests truthfully.