I, __________ [name of person making declaration], declare:
1. I am __________ [a party to this __________ (action or
proceeding) appearing in propria persona or the attorney of
record for __________ (name of party), the __________ (plaintiff
or defendant) in this __________ (action or proceeding)].
2. I am propounding the attached Requests for Admission,
Set Number _____, to __________ [name of responding party], the
__________ [plaintiff or defendant] in the above cause of
action.
3. Propounding this set of requets to __________
[plaintiff or defendant] will cause the total number of requests
propounded by __________ [propounding party] to __________
[plaintiff or defendant] to exceed the number of requests
permitted by section 2033(c)(1) of the Code of Civil Procedure.
4. To date, I have propounded a total of _____ admission
requests to this party.
5. Set Number _____ contains a total of _____ requests for
admission.
6. I am familiar with the issues presented by this case,
and the previous discovery conducted by all parties in the case.
7. I have personally examined each of the requests in Set
Number _____.
8. The additional number of requests for admission
contained in Set Number _____ is warranted under section
2033(c)(2) of the Code of Civil Procedure because __________
[state reasons why complexity or quantity of issues in lawsuite
warrants additional requests].
9. __________ [Requesting party] has not served the
requests for admission contained in Set _____ for an improper
purpose, such as to harass __________ [responding party or
responding party's attorney], or to cause unnecessary delay or
a needless increase in the cost of litigation.
I declare under penalty of perjury under the laws of
California that the foregoing is true and correct, and that this
declaration was executed on __________ [date].
