(See Fed. R. Civ. P. 34)

LR 34-1 Requests for Production - Generally

(a) Not Filed With the Court (See LR 5-9)

Unless directed by the Court, requests for production will not be filed with the Court. Instead they will be maintained by counsel and made available to parties upon request. Requests for production presented for filing without Court approval will be returned to the offering party. To facilitate responding, a courtesy copy of the requests for production must be e-mailed concurrently pursuant to LR 5-9(b).

(b) Use of Non-Filed Requests

This rule does not preclude the use of requests for production and responses as exhibits or evidence in support of a motion, or at trial, subject to appropriate rules of evidence.

(c) Definitions

Each request must state in concise language the information requested. In no case may a request refer to a definition not contained within the request or the preamble. Only terms actually used in the request for production may be defined.

LR 34-2 Responses and Objections (See Fed. R. Civ. P. 34(b)(2))

Responses must set forth each request in full before each response or objection.
When an objection is made to part of a request for production, a response must be made to the remainder of the request at the time the objection is made, or within the period of any extension of time to respond, whichever is later.

Amendment History to LR 34
June 1, 2006
LR 34.1(a)	The first sentence divided into two sentences. The sentence "Requests for production shall be served . . . ." added.
LR 34.1(b)	The words "for introduction" stricken.
LR 34.3	Cross-reference to LR 26.7 added and text deleted.
LR 34.5	The words "With Order Compelling Production" added to heading. Cross-reference updated.
December 1, 2009
LR 34-1(a)	Removed the language that requests for production "shall be served pursuant to Fed. R. Civ. P. 5" and inserted text, "To facilitate responding, a courtesy copy of the interrogatories must be e-mailed concurrently...." The word "will" substituted for "shall."
LR 34-2	Corrected Fed. R. Civ. P. 34(b) reference to 34(b)(2).
LR 34.3	Removed as a rule without a rule.
LR 34.4	Removed as a rule without a rule.
LR 34.5	Removed as a rule without a rule.
March 1, 2014
LR 34-1	In the caption, updated cross-reference from "LR 5-2" to "LR 5-10." In the rule text, updated cross-reference from "LR 5-2(b)" to "LR 5-10(b)."
March 1, 2016
LR 34-1(a)	In the caption, updated cross-reference from "LR 5-10" to "LR 5-11." In the rule text, updated cross-reference from "LR 5-10(b)" to "LR 5-11(b)."
LR 34-2(a)	Deleted the second sentence.
January 1, 2019
LR 34-1(a)	In the title, updated the cross-reference from "LR 5-11" to "LR 5-10." In the rule text, updated the cross-reference from "LR 5-11(b)" to "LR 5-10(b)."
January 21, 2020
LR 34-1(a)	In the title, updated the cross-reference from "LR 5-10" to "LR 5-9." In the rule text, updated the cross-reference from "LR 5-10(b)" to "LR 5-9(b)."