Can You Propel Document Requests to Support Admissions in California?

Question from Bey, Can You Propel Document Requests to Support Admissions in California?

Answer from AI:

In California, a party may indeed serve a request for production of documents to obtain the evidence that supports an answer to a request for admissions. The discovery statutes give the requesting party the tools to compel the production of any non‑privileged material that is relevant to the issues in the case and that can lead to admissible evidence.

How Requests for Admissions and Production Interact

• Requests for Admissions (RFA) – Under CCP § 2033.210, a party must admit, deny, or state that they lack sufficient knowledge to admit a matter. When a party answers “admit” or “deny,” the opposing party may still need the underlying documents to verify the truth of the admission or to challenge a denial.
• Requests for Production (RFP) – CCP § 2031.010 permits a party to request any documents, electronically stored information, or tangible things that are relevant to any claim or defense. The request must describe the items with reasonable particularity.

Because the statutes operate independently, an RFP can be used at any point in the discovery window to obtain the documents that the responding party relied on when answering an RFA.

Procedural Requirements

When propounding an RFP to substantiate an RFA answer, keep these points in mind:

1. Specificity – Identify the documents with enough detail to avoid a “overly broad” objection (e.g., “all e‑mail communications between John Doe and XYZ Corp from Jan. 1 2022 through Dec. 31 2022 concerning product safety”).
2. Relevance – Show that the documents are “reasonably calculated to lead to the discovery of admissible evidence” (CCP § 2031.010).
3. Form of Production – State whether you want originals, copies, or electronic files in a particular format.
4. Timing – Serve the RFP within the discovery schedule set by the court or the parties’ stipulation; otherwise, the request may be deemed untimely.
5. Objections – The responding party may object on grounds of relevance, privilege, undue burden, or that the request is vague. If an objection is made, the parties may need to meet and confer or seek a protective order.

Sample Language

“Produce all documents, including e‑mail messages, internal memoranda, and product testing reports, that support your answer to Request for Admission No. 3, which states that you were aware of the defect in the Model X widget prior to its commercial release.”

Key Cases and Guidance

• Kelley v. Superior Court (1995) 10 Cal.App.4th 1245 – The court affirmed that a request for production may be used to obtain documents that a party relies on in admitting or denying a factual allegation.
• California Rules of Court, Rule 3.1340 – Provides the framework for meeting and conferring when discovery disputes arise.

Practical Tips

• Combine Requests – It is common to serve the RFA and the related RFP together, referencing the specific admission each set of documents is meant to support.
• Document Preservation – Once a request is served, the responding party must preserve the requested materials; failure to do so can lead to sanctions under CCP § 2023.030.
• Privilege Log – If the responding party withholds documents on a privilege claim, they must provide a privilege log describing the nature of each withheld item.

When to Seek Legal Advice

While the statutes above outline the general rules, the precise wording of an RFP, the assessment of relevance, and the handling of objections can be nuanced. Parties should consult a licensed California attorney to tailor discovery requests to the specific facts of their case and to ensure compliance with any local court orders or deadlines.

For the full text of the discovery statutes, see the California Code of Civil Procedure (sections 2031‑2033) and the California Courts’ discovery guide.