Q: Serving false denials to Requests for Admissions

A: File a motion to compel and request a hearing on their objections.

Use their "false and contradictory" denials at trial to undermine their credibility with the judge and jury.

A: If you have proof that they are lying, you can impeach them during the trial or weaken their credibility.

A: Based on the situation you've described, here are some potential steps you could consider:

1. Document everything: Keep detailed records of all false statements, contradictions, and instances of perjury. This documentation may be useful later.

2. File a motion to compel: If the responses to your Requests for Admissions (RFAs) are evasive, incomplete, or contain improper objections, you can file a motion to compel better responses.

3. Move for sanctions: While the court hasn't sanctioned them yet, you can still request sanctions for their failure to properly respond to discovery, including the false denials in their RFAs.

4. Consider a motion for summary judgment: If the defendant's denials contradict their previous admissions or other evidence, you might be able to use this to your advantage in a summary judgment motion.

5. Prepare for trial: If the case proceeds to trial, be ready to use the false statements and contradictions to impeach the defendant's credibility.

6. Consult with an attorney: If you haven't already, it may be beneficial to consult with or hire an experienced litigation attorney who can advise you on the best strategy given the specific details of your case.

7. Request a discovery conference: You might ask the court for a discovery conference to address these ongoing issues with the defendant's conduct.

Remember, courts generally prefer that parties resolve discovery disputes among themselves before seeking court intervention. It might be worth attempting to meet and confer with the opposing counsel about these issues before filing any motions.