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Rule 34(a) enables a party to produce and permit the requesting party or its representative to inspect, copy, sample, or test any designated documents or ESI?including drawings, writings, graphs, charts, sound recordings, photographs, images, and other data or data compilations.
Rule 34 of the Federal Rules of Civil Procedure provides for discovery and inspection of documents and things in the course of developing a case for trial. Subsection (b)(1)(A) states that the request must ?describe with reasonable particularity each item or category of items to be inspected.? See Fed. R. Civ.
The summary judgment procedure under Rule 56, Federal Rules of Civil Procedure, which is identical to Rule 56, Montana Rules of Civil Procedure, was intended to provide a method of promptly disposing of actions in which there is no genuine issue of any material fact.
FRCP 26(a)(1)(A)(ii) requires parties to provide a ?a copy?or a description by category and location?of all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custody, or control and may use to support its claims or defenses, unless the use would be solely ...
If a pleading sets out a claim for relief that does not require a responsive pleading, an opposing party may assert at trial any defense to that claim. No defense or objection is waived by joining it with one or more other defenses or objections in a responsive pleading or in a motion.
A party claiming relief may move, with or without supporting affidavits, for summary judgment on all or part of the claim. (b) By a Defending Party. A party against whom relief is sought may move, with or without supporting affidavits, for summary judgment on all or part of the claim.
The rule provides that a request for inspection shall set forth the items to be inspected either by item or category, describing each with reasonable particularity, and shall specify a reasonable time, place, and manner of making the inspection.
Rule 34. Producing Documents, Electronically-Stored Information, and Tangible Things, or Entering onto Land, for Inspection and Other Purposes.