united-states federal-courts discovery
discovery objections
<p>suppose a party is seeking discovery on an opponent.</p>

<p>The opponent refuses to answer discovery because they say "irrelevant, not related to the claims".  </p>

<p>If the opponent does that on interrogatories the correct course is to motion the court to compel answers by telling the court how those interrogatories are specifically relevant.</p>

<p>So, if the issue is over request for admissions and the opponent claims "irrelevant, not related to the claims" what is the proper course here?</p>

<p>A party could do a motion to deem matters admitted.  But how much of, if any, detail about relevance should the party put in their motion to deem matters admitted?  Some people claim that all request for admissions are relevant if they concern any aspect of the case.  So, how much of if any detail concering relevance should go into a motion to deem matters admitted?</p>

<p>I am adding the following.
The problem seems to be the statement "a party can not object as irrelevant without more".<br>
Well, is there more if the objection contains; "not related to the claim".<br>
So, is this the statement that puts the shoe on the other foot?<br>
Does this statement put the burden of proof of relevance on the requester and require excruciating detail to prove relevance? 
    The consensus seems to be, any request is relevant if it will lead to discoverable evidence or facts.  And these cases are not going into the DETAILS of why the RFA's are relevant in their particular case.
    So, the question is if a person were to do a motion to determine sufficiency of responses without stating EXACTLY why the responses are relevant and merely stating that all RFA's are relevant, would they be wasting their time or would they be preserving their legal strategy?
    In regards to RFA's, is the responding party drawing a legal conclusion by responding with, "objection, not related to the claim"?</p>

<p>You could bring a motion to compel for failing to respond substantively to a motion to admit which is objected to, just as you could for an interrogatory. The process is the same.</p>

<p>Normally, a request to admit would not be deemed admitted if a substantive objection was filed by the deadline, even if there was no express admission or denial. Only if the objection were completely and utterly meritless would a judge be likely to order that the request to admit would be deemed admitted in that case since the response was a <em>de facto</em> non-answer and the objection was a mere sham.</p>

<p>@Iñaki Viggers states in his answer:</p>

<blockquote>
  <p>the purpose of a request for admissions is [to attempt] to stipulate
  --rather than to discover-- the facts on which plaintiff and defendant agree.</p>
</blockquote>

<p>This is not really true. </p>

<p>A request to admit is a discovery tool to prevent you from having to prove up what should be non-controversial facts that might nonetheless take time or documentation to prove at trial and to gather evidence for in advance of trial. The questions in a request to admit are typically ones that the other side would not willingly stipulate to (for example, because they'd like to be able to offer testimony to explain a seemingly unfavorable fact) but may not be able to deny.</p>

<p>If a party denies a request to admit and then offers nothing to support the denial in discovery practice or at trial, that party risks court sanctions for the groundless denial.</p>

<p>Good litigation practice is also always to include some requests to admit that are effectively outcome determinative to give the opposing party a chance to screw up and essentially default the case by not responding on time.</p>
