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Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. The propounding (requesting) party must include enough information to make the requested documents easily identifiable.
Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor's behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information ...
Definition: A written list of documents, electronic files, and audio and video recordings or physical things, submitted to a party from his or her adversary to inspect and copy the requested items and that have relevance to the issues in a lawsuit.
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.
What Is a Request for Production of Documents? A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
Rule 34(b) provides that a party must produce documents as they are kept in the usual course of business or must organize and label them to correspond with the categories in the discovery request.
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.
A party may serve on another party - no later than 30 days before the end of the discovery period - a request for production or for inspection, to inspect, sample, test, photograph and copy documents or tangible things within the scope of discovery.