request for admissions deemed admitted

Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! (c) The court shall make this order, unless it finds that the party to whom the requests that both of the following conditions are satisfied: (1) The party has subsequently served a response that is in substantial compliance Fla. R. Civ. (See Exhibit #5.) Guide: Civil Procedure Before Trial (TRG 2020), 8:1378 citing Wimberly v. Derby Cycle Corp. (1997) 56 Cal. (Code Civ. Your credits were successfully purchased. Motion to Deem Requests for Admissions and Genuineness of Documents Admitted In lieu of, or in addition to, this order, the court may impose a monetary sanction Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 2033.280 - last updated January 01, 2019 You should consult an attorney for advice regarding your individual situation. If you have not received responses to your Requests for Admissions, then you can file the motion. We have notified your account executive who will contact you shortly. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Getting calls from LibertyAP? 2033.280(b).) We noticed that you're using an AdBlocker. Stay up-to-date with how the law affects your life. Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. You will lose the information in your envelope, Order Filed Re: - ORDER ON PLAINTIFFS MOTION TO DEEM FACTS ADMITTED FILED. If necessary you may need to ask the court for a continuance on the motion for summary judgment to give you the time you need. We will email you Plaintiff further seeks as a sanction attorneys fees for the filing of this motion and its efforts to seek compliance with Massachusettss discovery rules. Singer v. Nationwide Fire Ins. If such responses are not provided, the court will award sanctions of $2,440.00 against Minghella and his counsel. Your email address will not be published. Your alert tracking was successfully added. Adding your team is easy in the "Manage Company Users" tab. Yet Defendant still refused to answer Plaintiffs complaint and discovery. Where the court grants a motion to compel responses, sanctions shall be imposed against the party who unsuccessfully makes or opposes a motion to compel, unless the party acted with substantial justification or the sanction would otherwise be unjust. Check your local rules, but generally your adversary has 30 days to respond to your Request for Admissions. A California Court of Appeal has stated in a published case that there is no requirement for an informal meet and confer attempt before a party may bring a motion for an order establishing admissions. Requests for Admissions are Deemed Admitted or (2) . In the Admission and Summary Judgment Motion, Plaintiff requested that its Request for Admissions be deemed admitted due to Defendant's failure to respond to that Request for Admissions. Furthermore, if a defendant has not opposed the motions and not responded to the subject discovery, the defendant will have waived any objections to the aforesaid discovery, which could result in the court allowing requested facts to be admitted. The request for admission shall not exceed 30 requests, including all subparts, unless the court permits a larger number on motion and notice and for good cause, or the parties propounding and responding to the requests stipulate to a larger number. Last. (See Exhibit #1.) Ct. (1972) 22 CA 3d 812 at page 815 the Second District Court of Appeal stated, We do not see, however, how any court can force a litigant to admit any particular fact if he is willing to risk a perjury prosecution or financial sanctions. That the statements contained in the request for admission should be deemed admitted by reason of defendants' failure to answer the same as provided in said . 117, 120 (1997). You will likely need to file more than once to win your case in court. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. when new changes related to " are available. If the court determines that an answer is insufficient, the court shall order either that an amended answer be served or that the matter be deemed admitted. PEPLPs motion for summary judgment is based on facts that it knew 22 months before the motion was filed. 6 1 Plaintiff received an e-mail from NEPLPs counsel indicating that these responses were forthcoming the day before this motion was filed. Should you withdraw your motion if the other side has complied? Vaxter, Shantanice D, Top Ten Dirt Bag Debt Collectors DisHonorable Mention, Can a person sue the furnisher of information if they falsely report on a Credit Report? Defendant Crenshaw Manufacturings Motion to Deem Admitted Requests for Admissions, Set One is granted. https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2033-290/, Read this complete California Code, Code of Civil Procedure - CCP 2033.290 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', The Onion Joins Free-Speech Case Against Police as Amicus, Bumpy Road Ahead for All in Adoption of AI in the Legal Industry. 1981). 13785 Research Blvd, Suite 125 All rights reserved. Asea, Inc. v. Southern Pacific Transp. 8 (Code Civ. Hearing Date: October 4, 2018 The trial court has the authority to order a matter admitted when it has been demonstrated that a party has intentionally disregarded the obligations imposed by Rule 36. Contacting us does not create an attorney-client relationship. Stay up-to-date with how the law affects your life. (1) Scope. They are currently arriving within 30 minutes of purchase. Please wait a moment while we load this page. Defendant. Permit Application Fee: $400.00 Check shall be made payable to "Miami-Dade County". A party may serve on any other party a written request to admit, for purposes of the pending action only, the truth of any matters within the scope of Rule 26 (b) (1) relating to: (A) facts, the application of law to fact, or opinions about either; and. This motion is quick and dirty. (a) Scope and Procedure. in the jurisdiction of Hillsborough County. (St. Mary v. Superior Court (2014) 223 Cal.App.4th 762, 776 (service of substantially compliant responses prior to the hearing on the deemed admitted motion will defeat a propounding partys attempt to have the requests deemed admitted). They have not filed an answer, have refused to admit or denyrequests for admission, and have failed to answer interrogatories and requests for production of documents. Representing Yourself (Pro Se)? Another California Court of Appeal has stated in a published case that there is not time limit on filing a motion to have the matters deemed admitted. Why You Need to Bring that Motion To Compel Further Responses to Interrogatories. A motion for an order having the matters specified in requests for admission deemed admitted in California can be filed when a party has failed to respond to the requests for admission. (See Exhibit #8 which demonstrates that 27 months ago, PEPLPs knew all of the facts upon which bases its motion for summary judgment.) Law authorizing requests for admission deemed admitted in California. Your subscription was successfully upgraded. 2033.230 " are filed before the hearing. Notably, under Rule 36(a)(3), requests for admission are automatically deemed admitted in U.S. federal courts if the opponent fails to timely respond or object. A motion for an order having the matters specified in requests for admission deemed admitted in California can be filed when a party has failed to respond to the requests for admission. 203328003.) Directions. The following are common times for deemed admissions to become an issue: McHam Law Requests for admission under Rule 36 can be an effective tool in discovery to confirm essential information or to force the opposition to clarify an ambiguous position. Wait about a week for their responses (if any) to get back to you. The motions judge is required to look at "the pleadings, depositions, answers to interrogatories and admissions on file, together with the affidavits, if any" to determine if summary judgment is proper. The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. Ralph C. Stoddard It also has legal malpractice overtones to it because someone screwed up by not getting the answers in on time and the ramifications for their client are harsh. Current as of January 01, 2019 | Updated by FindLaw Staff. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. 2033.280has teeth! SUPERIOR COURT CIVIL DEPARTMENT CIVIL ACTION NO: 00-4988G, NEW ENGLAND PATRIOTS LIMITED PARTNERSHIP, BERTRAM ZARINS, M.D., MICHAEL G. WILSON, M.D., AND RONALD ONEIL. Required fields are marked *. Your alert tracking was successfully added. A motion for summary judgment alleges that the moving partys case has already been proved to the level that the court has no choice but to rule in favor of that party. Cassesso v. Commissioner of Correction, 390 Mass. (2) In lieu of a separate statement required under the California Rules of Court, (a) On receipt of a response to requests for admissions, the party requesting admissions may move for an order compelling a further response if that party deems that either or both of the following apply: (1) An answer to a particular request is evasive or incomplete. R. Civ. If the court determines that an answer is insufficient, the court shall order either that an amended answer be served or that the matter be deemed admitted. As set forth below, this Court should grant judgment on behalf of the Plaintiff because over two years have passed and the Defendant has refused to respond to the core allegations in Plaintiffs Complaint. to compel further response, unless it finds that the one subject to the sanction acted (2) An objection to a particular request is without merit or too general. LaLonde v. Eissner, 405 Mass. The subject discovery requests were personally served on 5/7/18. This is the only place in the Discovery Act that imposes MANDATORY sanctions. ), The failure to respond is a misuse of the discovery process, and sanctions may be warranted. Be sure to quote from the relevant rule of civil procedure. Mass. 2031.300(a), 2033.280(a-b). for admission necessitated this motion. During Summary Judgment. may move for an order compelling a further response if that party deems that either (b) The requesting party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted, as well as for a monetary sanction under Chapter 7 (commencing with Section 2023.010). 2033.280(c). A request for admission may relate to a matter that is in controversy between the parties." Code Civ. Incredibly, NEPLP does not feel similarly constrained, serving requests for admission on October 2, 2002, that were timely answered by Plaintiff. Although the matters subject to such request under Rule 36 are somewhat broader than those under the statute, Rule 36 should cause no difficulty; to . 2033.280(a)(1)-(2).) https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2033-280/, Read this complete California Code, Code of Civil Procedure - CCP 2033.280 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', The Onion Joins Free-Speech Case Against Police as Amicus, Bumpy Road Ahead for All in Adoption of AI in the Legal Industry. Case No. The matter is admitted unless, within 30 days after service of the request, or within such shorter or longer time as the court may allow, the party to whom the request is directed serves upon the party requesting the admission a written answer or objection addressed to the matter, signed by the party or by the party's attorney, but, unless the (See Exhibit #8.) (a) Scope; service; answer or objection; motion to determine sufficiency. When Do I Have to Bring a Motion to Compel Written Discovery? Callous disregard of discovery responsibilities cannot be condoned. Using discovery to reach evaluation, mediation and trial goals. We invite you to contact us and welcome your calls, letters and electronic mail. On June 18, 2019, Petitioner Mid-Century Insurance Company (Petitioner) petitioned the Court to assign a case number for the purpose of enforcing discovery in an uninsured motorist arbitration proceeding pursuant to Insurance Code Section 11580.2(f). (c) The court shall make this order, unless it finds that the party to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial compliance with Section 2033.220. (1) The normal time for response to a request for admissions is lengthened from 10 to 30 days, conforming more closely to prevailing practice. 2033.220 and C.C.P. Requests for Admissions ("RFAs") permit any party to request any other party to admit: (1) the truth of specified matters of fact, opinion relating to fact, or application of law to fact; or (2) the genuineness of specified documents. In a hearing or at trial. Over two years after it was served with process, NEPLP has yet to file an answer to Plaintiffs Complaint in this case. Pederson v. Time, Inc., supra at 17. If the application is approved by the ERM, an operating permit fee will be required prior to issuance of the permit. Rule of Court Changes for Remote Depositions, You Harm Your Clients Interest When You Craft or Transmit Evasive Discovery Responses. Proc., 2033.290. On September 10, 2002, almost two years after this case was filed, the NEPLP filed a motion for summary judgment alleging facts that were available to it for more than 22 months. Your subscription has successfully been upgraded. See Cal. This court has the power to sanction a defendant by deeming admitted Plaintiffs Request for Admission. They are written in a yes or no format that does not allow for explanations. Unless the court determines that an objection is justified, it will order that an answer be served. Your credits were successfully purchased. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2033-280/. (Code Civ. You can always see your envelopes Reporter's notes. (Code Civ. will be able to access it on trellis. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Copyright 2023, Thomson Reuters. Part FOUR - Pretrial Procedures, Dispositions and Production at Trial, Rule 4:10 - Physical and Mental Examination of Persons, Rule 4:12 - Failure to Make Discovery; Sanctions. with Section 2023.010) on the party or attorney, or both, whose failure to serve a timely response to requests Track Judges New Case, Geovera Specialty Insurance Company Plaintiff Anchor Bay Entertainment, LLCs Motion to Deem Facts Admitted shall be GRANTED if code-compliant and objection-free responses are not served by the date of hearing on this motion. and Towson; Carroll County including Westminster; Frederick County including Frederick; Harford County including Abingdon, Bel Air, Belcamp, and Forest Hill; Montgomery County including Germantown and Rockville; Howard County including Ellicott City and Columbia, Washington, D.C. and Washington County including Hagerstown. It is a gotcha motion. Also, in case you missed out and have not propounded your Request for Admissions, here is an example. The discovery deadline has been extended from December 28, 2002 to June 1, 2003. If objection is made, the reasons therefor must be stated. Kourouvacilis v. General Motors Corp., 410 Mass. 419, 422, 456 N.E.2d 1123 (1983); Community Nat'l Bank v. Dawes, 369 Mass. However, no sanctions can be imposed for delay in responding to Requests for Admissions if answers were provided prior to the filing of the motion. 419, 422, 456 N.E.2d 1123 (1983); Community Nat'l Bank v. Dawes, 369 Mass. Unlike the other discovery statutes dealing with the failure to respond, C.C.P. P., Rule 36. If the court determines that an answer does not comply with the requirements of this Rule, it may order either that the matter is admitted or that an amended answer be served. Fla. R. Civ. Admitting that the unanswered requests were deemed admitted under Iowa Rule of Civil Procedure 1.510 (2), the son moved to withdraw his admissions. There are three parts of Discovery you can propound on your adversaries: This post is going to look at Admissions. P. 1.370(a). 706, 716, 575 N.E.2d 734 (1991); Pederson v. Time, Inc., 404 Mass. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. The court, on motion, may relieve that party from this waiver on its determination Div. 4 with Sections 2033.210, 2033.220, and 2033.230. We have notified your account executive who will contact you shortly. When Ms. Park failed to timely respond, the requests were conclusively admitted. Moreover, Plaintiff has been prejudiced because discovery against the Patriots might yield meaningful evidence on the other defendants. Proc., 2030.290; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 403.) (c) Unless notice of this motion is given within 45 days of the service of the verified This Blog/Web Site is made available by the lawyer or law firm publisher for educational purposes only as well as to give you general information and a general understanding of the law, not to provide specific legal advice. Motion to Compel Further Responses & Production of Documents Proc. R. Civ. Requests for admission are written requests sent during the discovery process of a lawsuit. If this were the case, every defendant would wait a few years before investigating a lawsuit because they might have a valid motion for summary judgment. Oh Decl., 5, 8 and Pliner Dec. in support of Reply 7 - 9. to the requests, including one based on privilege or on the protection for work product You will lose the information in your envelope, VAXTER, CHRISTOPHER J et al vs GEOVERA SPECIALTY INSURANCE COMPANY. The answer must specifically deny the matter or set forth in detail the reasons why the answering party cannot truthfully admit or deny the matter. Proc. Requests for admission. R. Civ. We noticed that you're using an AdBlocker, MOTION TO - FOR - DEEM REQUESTS FOR ADMISSIONS ADMITTED. If you wish to keep the information in your envelope between pages, ), Where a party fails to timely respond to a request for admission, the propounding party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted. For full print and download access, please subscribe at https://www.trellis.law/. Before the case was remanded, NEPLP filed an answer in federal court, refusing to admit or deny the allegations made against it. Attorneys or parties in the State of California who wish to view a portion of a sample motion for an order having matters deemed admitted containing brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail sold by the author can use the link shown below. (1) A party may serve upon any other party a written request for the admission, for purposes of the pending action only, of the truth of any matters within the scope of subsection (b) of Code Section 9-11-26 which . (b) The requesting party may move for an order that the genuineness of any documents The party requesting the admission may move to determine the sufficiency of an answer or objection that it deems insufficient. You have to request that the Motion be placed on a . They will then pull the deemed admissions out at a hearing or trial as a surprise. One or two word search terms work best. ********************************* 4. 2033.290(e).) (c) The court shall make this order, unless it finds that the party to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial compliance with Section 2033.220. Proc., 2033.210. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. The information you obtain at this site is not, nor is it intended to be, legal advice. Plaintiff propounded interrogatories and document requests on October 2, 2002, in spite of repeated request to receive these answers (see Exhibits #11, #12, #13, #14, #15, and #16) and assurances that he would receive responses. Remember: A deemed admittedorder establishes by judicial fiat, that a non-responding party has responded to the requests by admitting the truth of all matters contained there. Cal. Mass. E. Application Fee . for admission have been directed has served, before the hearing on the motion, a proposed against %PDF-1.5 % Motions to Com ..to serve responses. See California Rule of Court 3.1345(b). admitted. The manner with which you handle deemed admissions depends on when you discover the issue. Defendants responses do not comply with the Code because they do not state whether the production w ..ce of ruling. The contact form sends information by non-encrypted email, which is not secure. Contact us. Contact us. under Section 2016.040. Yet, there are benefits in choosing this motion. (See Exhibit #6.) All of them have their place in your discovery plan but two of themMotion to Compel Further Responses and Motions to Have Matters Deemed Admitted must be in your arsenal. MOTION TO - FOR - DEEM REQUESTS FOR ADMISSIONS ADMITTED December 17, 2019. 7 Unless the responding party states an objection or asserts a privilege, the responding party must specifically admit or deny the request or explain in detail the reasons that the responding party cannot admit or deny the request. Under Code of Civil Procedure 2033(k), a court must grant a motion to have admission requests deemed admitted where legally sufficient responses have not been served prior to the hearing on the motion. If a party to whom requests for admission are directed fails to serve a timely response, (See Exhibit #5.) Mass. The court, on motion, may relieve that party from this waiver on its determination that both of the following conditions are satisfied: (1) The party has subsequently served a response that is in substantial compliance with Sections 2030.210, 2033.220, and 2033.230. P., Rule 56(c); Cassesso v. Commissioner of Correction, 390 Mass. Also, add 3 days for mailing. 267 Motion for Admissions be Deemed Admitted This motion is quick and dirty. A denial must fairly meet the substance of the requested admission, and when good faith requires that a party qualify his answer or deny only a part of the matter of which an admission is requested, he must specify so much of it as is true and qualify or deny the remainder. A motion to have the matters specified in requests for admission deemed admitted in California is also known as an order establishing the truth of each matter specified in the requests for admissions that were served on the other party. Where a party fails to provide a timely response to requests for admission, [i]t is mandatory that the court impose a monetary sanction under Chapter 7 (commencing with 2023.010) on the party or attorney, or both, whose failure to serve a timely response to requests for admission necessitated this motion. (Code Civ. For example, you can write: "According to Utah Rule of Civil Procedure 36(A), each Request for Admission is admitted unless the party to whom the requests were directed serves a written . This is so even when the defendants served a verified response before the continued hearing date. Admission and Summary Judgment Motion and Brief in support thereof, were filed by Plaintiff. (Code Civ. As briefly as possible, explain why the judge should deem your Request for Admissions as admitted. By bringing a Motion to Compel Answers to Requests for Admissions the propounding party gets the answers they want, keeps peace during the litigation and prevents the discovery process from escalating to an all-out war. The nonmoving party cannot defeat the motion for summary judgment by resting on its pleadings and mere assertions of disputed facts. or excusable neglect. However, Ms. Park had moved to withdraw the admissions. It is not uncommon for the attorney who sent the requests for admissions to not mention that no response was made. We are currently collect data for this state. There are no time limitations in bringing the motion. (Code Civ. If a party fails to serve a timely response, the requesting party may move for an order that the requests be deemed admitted. Here is an example: DECLARATION IN SUPPORT OF MOTION TO DEEM FACTS ADMITTED. R. Civ. App. If you mailed the Requests for Admission, they have 33 days since the date they were mailed, to mail responses back to you. Requests for Admission are deemed admitted unless the party to whom the requests are directed affirmatively admits or denies the request within 30 days after service of the request of being served. Please indicate below the reason for your request (check all that apply): Change in Income Summary judgment is appropriate if the moving party shows that "there is no genuine issue of material fact and that [he] is entitled to judgment as a matter of law." Hbd`ab`ddwwqv/-L- )f!CGwOYe~&f!&F2dMCKK ii & 4f`LZ(8'*W+x%%)(8(L.VJ-N-*\l@001032b}GA/9HPE~}k-+_'S)rGimq),]E" :(C`?r~]9YNVZa%asYg, (See Exhibit #4.) Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Your recipients will receive an email with this envelope shortly and You need to solve the problem before the hearing on the motion for summary judgment occurs. Requests for admissions are very useful in that they allow a party to get certain admissions or denials of issues relevant to the lawsuit on record before the trial, as well as authenticating certain documents. Proc. You can always see your envelopes Proc. Deemed admissions are an excellent basis for a motion for summary judgment because they are considered to be statements by the party that failed to respond that admit guilt or at least the elements that the moving party must prove in order to win the motion for summary judgment. Oh Decl., 4; Exhibits A - C. The proofs of service establishing personal service are attached as Exhibits B and C. Plaintiff did not and has not served responses. under Chapter 7 (commencing with Section 2023.010). RFAs are a powerful trial-preparation tool. Notify me of followup comments via e-mail. the following rules apply: (a) The party to whom the requests for admission are directed waives any objection If this happens you should immediately request a continuance to address the admissions. the truth of any matters specified in the requests be deemed admitted, as well as for a monetary sanction under Chapter 7 (commencing with Section 2023.010). However, in the event that Plaintiff serves a proposed response to the requests for admission that is in substantial compliance with Code of Civil Procedure section 2033.220 before the time of the hear ..to the requests for admission that is in substantial compliance with Section 2033.220. when new changes related to " are available. The U.S. District Court rejected both grounds and the case was remanded to this Court. (2) The partys failure to serve a timely response was the result of mistake, inadvertence, or excusable neglect. (Code Civ. Code Civ. Co., 512 So. Only terms actually used in the request for admission may be defined. This can have horrible consequences in your case as the other side may use these deemed admissions against you either at trial or at a summary judgment hearing. The answer filed by NEPLP in federal court is not much better than its refusal to answer in state court. Id; Sabian v. Gentle Movers, 1997 Mass. Motion for Admissions to be Deemed Admitted may be filed pursuant to C.C.P. Accessing Verdicts requires a change to your plan. A response must fairly meet the substance of the request. Prac. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. party waives any right to compel further response to the requests for admission. NEPLP has willfully ignored this requirement by making no effort whatsoever to inquire into the merits of this lawsuit. The matter is admitted unless, within 30 days after service of the request, or within such shorter or longer time as the court may allow, the party to whom the request is directed serves upon the party requesting the admission a written answer or objection addressed to the matter, signed by the party or by his attorney, but, unless the court ), The court is authorized by statute to deem particular requests admitted if the responding party fails to comply with an order compelling further responses to RFAs. In Allen-Pacific, the defendants response to the RFAs provided prior to the initial hearing on plaintiffs motion failed to conform to the statutory prescription of Code of Civil Procedure 2033(g) because it was not signed by the individual defendant and was not under oath. (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion The most important thing about admissions is that there is a deadline by which they must be answered and if you fail to respond in a timely manner they are deemed admitted. 1973). Plaintiffs unopposed Motion to Compel Further Responses and Production of Documents as to Defendants VM Super Saiyan LLC and Brent Murakami is granted. Defendant has willfully ignored the plain language of Rule 36 that an answering party may not give lack of information or knowledge as a reason for failure to admit or deny unless he states that he has made reasonable inquiry and that the information known or readily obtainable by him is insufficient to enable him to admit or deny. The Rule further states that a matter may be deemed admitted if the answer "does not comply with the requirements of this rule.".

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