Rule 11, as it then existed, was modeled after its pre-1983 federal counterpart. In 1994 the text of Rhode Island Rule 11 read as follows: “Every pleading of a party represented by an attorney shall be personally signed by at least one (1) attorney of record * * *. The signature of an attorney constitutes a certificate by the attorney that he or she has read the pleading; that to the best of his or her knowledge, information, and belief there is good ground to support it; and that it is not interposed for delay.” Although an objection to a discovery request is not a pleading, it could be argued that Super. R. Civ. P. 7(b)(2) extended the reach of former Rule 11 to include the signing of objections to discovery requests. See Bergeson v. Dilworth, 132 F.R.D. 277, 287 (D.Kan.1990) (<HOLDING>). But even if former Rhode Island Rule 11 were
holding that requests for admissions are subject to discovery cutoff dates holding that the defendants discovery requests were untimely because they were not served in time for the responses to be due before the discovery deadline holding that plaintiff need not have submitted requests for admissions by the august 15 discovery motion cutoff date or by the discovery cutoff date of september 15 because requests for admissions are distinct from other general discovery devices and are not subject to discovery cutoff dates holding that the trial court grants or denies motions for summary judgment on the basis of what is contained in the motions for summary judgment and the responses thereto holding that the term other papers as defined in federal rules 7b2 and 11 refers to discovery motions interrogatories and requests for production and admissions and the responses thereto