Radtke v. Miller, Canfield, Paddock & Stone

We are required in this action for legal malpractice to clarify what constitutes an “admission” by a party under MCR 2.312(D)(2), so that use of the admission in other proceedings is not permitted. We hold that the term refers only to those statements directly within the scope of the request for admission, and does not cover statements that qualify or explain an admission, denial, or objection.

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This appeal is from the partial reversal of an order of summary disposition that favored defendant Miller Canfield in an action for legal malpractice. It stems from an underlying lawsuit brought by…