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Description
Underutilized and underappreciated, RFAs can accomplish things that other forms of discovery cannot. RFAs can effectively confirm essential facts in the case and alleviate the need for more expensive discovery.
RFAs are powerful in part because they are generally not limited to matters within the personal knowledge of the responding party, and the responding party must make a reasonable investigation before claiming a lack of information. In answering an RFA with a lack of knowledge response, the party should be prepared to testify as to why such an answer was provided at deposition.
Any matter deemed admitted is conclusively established, with narrow exceptions. For maximum effect, RFAs should be clearly and carefully drafted in light of the elements of the claims and defenses. RFAs should be appropriately timed and part of an overall discovery plan driving toward summary judgment or trial. Recycled RFAs or those that incorporate overbroad definitions can be self-defeating.
Listen as this distinguished panel guides counsel through how RFAs can make a big difference in the case, including reducing costs and laying the foundation for summary judgment.
Presented By

Compassion combined with trial experience, strategy, risk assessment, passionate communication, growth, relentless pursuit, and community involvement. These tools live at the top of Mr. Cooper's toolbox. As a writer, speaker, and communicator, Mr. Cooper absorbs information, distills it, and presents it persuasively to decisionmakers. The communication style he employs – simple, straightforward, and heartfelt – is the same winning method used by the team to help others comprehend the full extent of harm people have suffered. He shares this approach with others in the legal community through his legal practice column, Back Story, which has educated and entertained Plaintiff magazine’s readers monthly for over 10 years.

Mr. Flora focuses his practice on civil litigation for both plaintiffs and defendants. This ranges from personal injury to class actions and other complex litigation matters.

Ms. Frankenstein is a partner of Gunderson, Palmer, Nelson & Ashmore, LLP. She practices in the areas of Employment Law, Insurance Defense, General Litigation, Election Law, Governmental, Administrative, and Municipal Law.

Mr. Roth is widely regarded as one of the leading family law appellate specialists in California. He has over 30 years’ experience as an appellate practitioner and more than 25 published (and scores of unpublished) appellate opinions to his name. Robert has won twice in the California Supreme Court, and notably represented the successful respondent in In re Marriage of Ostler and Smith (1990) 223 Cal.App.3d 33, a seminal case that established the method California courts use every day to calculate division of bonus income. Mr. Roth was one of the first attorneys in California certified as an appellate specialist by the State Bar. He has remained a certified appellate specialist for more than two decades. In addition to family law appeals,Mr. Roth has substantial experience handling probate, real property, business transaction, tort insurance, admiralty, and State Bar appeals.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Live Online
On Demand
Date + Time
- event
Tuesday, January 30, 2024
- schedule
1:00 p.m. ET./10:00 a.m. PT
Outline
- Overview of FRCP 36 and state counterparts
- Timing, planning, and drafting productive RFAs
- Responding to RFAs and contending with evasive answers
- Enforcement and strategic use of RFAs
- Altering or amending responses to the admissions
Benefits
The panel will discuss these and other pivotal issues:
- Which issues are best suited for RFAs?
- How can counsel avoid unclear RFAs?
- What is an acceptable explanation for "lack of sufficient information" to admit or deny?
- Can facts incorrectly, but in good faith, admitted, be corrected?
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