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Hi and Thank you for requesting me,
In Answer to your questions,
1. A partial response will be good only as to those questions or admissions to which you have responded. It will not be satisfactory because you will be deemed to have admitted everything to which you have not responded;
2.& 3. Opposing counsel can give you an extension of time and there is no special form that is needed. One thing that I would do if I were you is to send a copy of the letter requesting an extension of time to the Judge's attention. When you receive a reply as to extending time to respond, I would send a copy of that letter also to the Judge's attention. This way, opposing counsel cannot pull a fast one and try file a Motion for Summary Judgment because you will have the letter granting the extension of time to respond and so will the Judge.
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All time limits prescribed by the Rules of Civil Procedure must be observed, otherwise the opposing side can ask for sanctions. The time limits can be extended if the opposing side agrees. Maybe, I am being overly cautious, but I would rather be cautious, than give the opposing side the upper hand. I would ask the opposing side for an extension of time and if they denied my request, I would ask the Court for an extension of time. However, if the opposing side granted the extension of time, I would still let the Court know - either by sending a copy of the letter to the Judge, or by filing the letter granting the time with the Court Clerk, if no Judge had yet been assigned - just so that the opposing side cannot do anything at some later time, saying that I missed the deadline, _____________________________________________________________________
1. You asked,
"Is it perfectly OK to file REquest for Admissions and file response for Reproduction of documents with the extended limit of 45 days instead of the Original 30 days that was given tome when discovery was seved."
You can use the extended period of time only to respond to the request for which the extension was given. For example, if you asked for an extension of time for the Production of Documents, then the extension of time refers only to that request and does not extend the time for the Request for Admissions;
2. You also asked,
"I have read that if you miss deadline to respond to request for production of documents ,you will get a second request for response to production of documents but responding to request for Admissions is super critical.is extended time of say 45 days is perfectly OK to file response to àdmissions?"
The opposing side does not have to make a second request. They can ask the Court for sanctions in several ways. For example, they can ask the Court not to allow you to give any evidence on the information which you did not respond to within the time limits allowed. And, a request for an extension of time to respond to one thing does not extend the time to respond to another. In other words, a request for an extension of time to respond to the Production of Documents, does not mean that you also have an extension of time to respond to their Request for Admissions;
3. Lastly, you asked,
'If the extension of two weeks is granted ,is it 100% safe to file response to both the requests with in extended time limit of say45 days"
It is safe, but if you do not trust the opposing side, make sure you have their granting you an extension of time in writing
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