Robinson

I.

FACTUAL AND PROCEDURAL

BACKGROUND

Robinson submitted a claim to State Farm for injuries sustained in an accident involving her car and an unidentified vehicle on the Carquinez Bridge. The claim was made under her insurance policy’s “uninsured driver” provision, and the parties agree that coverage was available only if the two cars came into contact. (See Ins. Code § 11580.2, subd. (b)(1).) An arbitration proceeding ensued, and State Farm propounded on Robinson a set of requests for admission. The set included eight requests, all seeking to advance State Farm’s defenses that there was either no contact between the two cars or that no damage resulted from any such contact. Robinson failed to respond by the due date, and State Farm filed a motion under section 2033.280 in the trial court to have the requests deemed admitted and for sanctions. After finding that Robinson had not “substantially complied” with sections 2033.220 or 2015.5—provisions governing responses to requests for admissions and the form of unsworn statements—the trial court deemed the requests admitted and awarded sanctions to State Farm. Robinson’s counsel subsequently moved under section 2033.300 to withdraw…