California  |  Business Law

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2/04/12, 8:39 am

Legal Question


I am a Defendant in a suit (unlimited) and have received Requests For Admission. In the "definitions" preceding the Requests, Plaintiff has clearly defined certain terms (ie YOU refers to me) used in the Requests, of which I fully understand. However, in several of the Requests, Plaintiff does NOT use the terminology defined in the "definitions" which are meant to dial into specific Requests but rather, has expressed the Requests rather vaguely. Example: Plaintiff has defined THE ACCOUNT as a specific bank account number, but the very first Request states, "Admit that you requested BANK to open an account on YOUR behalf." Over several decades, I have asked this bank to open 15+ different accounts, some opened and some denied. Because I'm being asked whether I requested to "open an account" which clearly does not refer to THE ACCOUNT, my proposed response is to, "Object on the grounds the Request is vague, ambiguous, overly broad, places and undue burden on Defendant to interpret the Request and is not properly limited as to time." There are several additional Requests that are very similar to which I would propose to respond to with the same objection. Does my objection and verbiage have validity other than to me? Thank you for any assistance you may provide...


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