Last year I was sued by my landlord on breach of contract (back rent) I immediately served interrogatories, production of docs,

Do you already have a prove-up hearing date set (or reserved)? If so, you need to serve the Request for Admissions at least 35 days prior to the hearing date to be able to use the RFAs. But based upon this former landlord's prior conduct in failing to respond to discovery and failure to comply with a discovery order, you will probably not receive responses to the RFAs in time for any prove-up hearing. I am not sure what you are trying to accomplish with your RFAs. In California, most default judgments are proven up via declarations (Code of Civil Procedure section 585) with the following exceptions where a live prove up is required by law: -- In non-contract actions where the defendant(s) have not been served by publication, the court must hear evidence of Plaintiff’s damages. (CCP 585 (b).) -- In all actions where the service of the summons was by publication. (CCP 585 (c).) -- In quiet title actions and in cases where the defendant has been served by publication and is a non-California resident. (CCP 764.010; Winter v. Rice (1986) 176 Cal.App.3d 679, 683; CCP 585 (c). However, a live prove-up hearing is sometimes an alternative method (which might be implemented if the plaintiff is representing himself or herself in pro per wherein the pro per plaintiff is likely to mess up on the procedural requirements).