Effective June 1, 2006

LR 34 REQUESTS FOR PRODUCTION (See Fed. R. Civ. P. 34)

LR 34.1 Requests for Production — Generally (See Fed. R. Civ. P. 34)

(a) Not Filed With the Court (See LR 5.2)

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. Requests for production shall be served pursuant to Fed. R. Civ. P. 5 and by e-mail in Word or WordPerfect format pursuant to LR 5.2(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))

(a) Responses must set forth each request in full before each response or objection. Each objection must be followed by a statement of reasons.

(b) 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.

LR 34.3 Waiver of Objections (See LR 26.7)

LR 34.4 Motions to Compel (See Fed. R. Civ. P. 37(a)(2)(B) and LR 37)

LR 34.5 Time Limits to Comply With Order Compelling Production (See LR 37.2)