§22.09 Request for Admission of Facts and of Genuineness of Documents

• Jurisdiction: Washington

§ 22.09 REQUEST FOR ADMISSION OF FACTS AND OF GENUINENESS OF DOCUMENTS

[1] Use and Scope

A written request for an admission of fact or the application of law to fact, including the genuineness of any documents, may be served upon the opposing spouse for the purpose of eliminating controversial matters that will not be disputed at the time of trial. CR 36. For example, counsel may use admissions to establish that certain property existed at the time of the marriage, that various assets were inherited or given to the client, or that a certain document accurately reflects the actuarial value of a spouse's pension. The scope of a request for admissions is also governed by CR 26(b) and gives the requesting party broad powers in obtaining information. CR 36.

[2] Procedure and Form

Written requests must be arranged so that after each separate request there is a blank space sufficient to enable the responding spouse to provide his or her answer. The request for admission cannot be included in the same document with other forms of discovery, such as interrogatories under CR 33 or requests for production of documents and things under CR 34. Copies of documents such as appraisals, actuarial evaluations, contracts, and deeds that are the subject matter of the...