"Requests for Admissions; Motion to Have Admissions Deemed Admitted"

After a long stretch of depositions, coupled with intense mediation sessions you finally have a day in the office to clean off your desk and catch up on your other cases Going through the stacks of mail, you find the motion with teeth -the Motion to Have Admissions be Deemed Admitted. Panic sets in. Now what do you do? The first thing you do is pick up the phone and call opposing counsel and beg for relief.
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There are three motions that you can bring–(1) Motion to Compel, (2) Motion to Compel Further Responses, and (3) Motion to have matters Deemed Admitted. All of them have their place in your discovery plan but two of them –Motion to Compel Further Responses and Motions to Have Matters Deemed Admitted must be in your arsenal. Though they appear to be the same motions you would use for interrogatories, inspection demands, and depositions there are a few noteworthy twists and turns.
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