Request For Admissions, Section 998: Prevailing Defendants Entitled To $108,000 In Costs-Shifting Under Section 998 And $39,140 For RFA Unreasonable Denials

Opinion Shows How Substantial Expenses Can Be Shifted.

               Doe v. Accor Hotels & Resorts, LLC, Case No. A167247 et al. (1^st Dist., Div. 3 July 21, 2025) (unpublished, posted on July 22, 2025) was where a prevailing defendant group won $108,000 based on a successful CCP § 998 offer and $39,140 (out of a requested $50,042.20, unilaterally reduced, wisely).  Those awards were affirmed based largely on abuse of discretion standards of review, with the appellate court rejecting very technical arguments on a section 998 offer where signature lines were provided for the litigant and litigant’s counsel.  Although we post broadly, this opinion shows that certain fee-shifting statutes and discovery sanctions statutes can be a nice win for the successful defendants.