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Monday, June 14, 2021

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Hon. Marco A. Hernández, Chief Judge

Mary L. Moran, Clerk of Court

LR 34 - Requests for Production

(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))

  1. Responses must set forth each request in full before each response or objection. 
  2. 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)." 

LR 1 - Scope and Purpose

LR 3 - Commencement of Action

LR 4 - Summons

LR 5 - Service and Filing of Pleadings and Papers

LR 5.2 - Redaction of Filings

LR 6 - Computing Time After Service

LR 7 - Motions Practice

LR 7.1 - Disclosure Statement

LR 10 - Form of Pleadings and Other Documents

LR 11 - Signature Requirements

LR 15 - Amended and Supplemental Pleadings

LR 16 - Pretrial Conferences, Scheduling, and Case Management

LR 23 - Class Actions

LR 26 - Discovery

LR 27 - Depositions: Before Action or Pending Appeal

LR 28 - Depositions in a Foreign Country

LR 29 - Stipulations About Discovery Procedure

LR 30 - Depositions

LR 33 - Interrogatories

LR 34 - Requests for Production

LR 36 - Requests for Admission

LR 37 - Motions to Compel

LR 38 - Right to a Jury Trial

LR 40 - Scheduling Cases for Trial

LR 41 - Dismissal of Action

LR 42 - Consolidation; Separate Trials

LR 45 - Subpoena

LR 47 - Selecting Jurors

LR 48 - Jurors and Participation in the Verdict

LR 51 - Instructions to the Jury

LR 54 - Bill of Costs and Attorney Fees

LR 55 - Default

LR 56 - Summary Judgment

LR 65 - Injunctions and Restraining Orders

LR 65.1 - Securities and Sureties

LR 67 - Deposits in Court

LR 68 - Offer of Judgment

LR 72 - Magistrate Judges: Pretrial Order

LR 73 - Magistrate Judges: Trial by Consent

LR 77 - Conducting Business; Clerk's Authority; Notice of an Order or Judgment

LR 79 - Records Kept by the Clerk

LR 81 - Habeas Corpus Petitions

LR 83 - Rules and Directives - By the District Court

LR 100 - Rule Governing CM/ECF: Case Management and Electronic Case Filing - Practices

Timetable for Lawyers