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Federal Litigation Guide
Copyright 2017, Matthew Bender & Company, Inc., a member of the LexisNexis Group.

2-14 Federal Litigation Guide 14.syn


Responding to Document Requests


Members of the Firm of Jenner & Block, LLC Chicago, Illinois: Michael T. Brody, Robert L. Byman, Timothy J. Chorvat, Clark C. Johnson, C. John Koch, Barry Levenstam, Matthew M. Neumeier, Jeffrey T. Sham, Jerold S. Solovy, and Howard S. Suskin.

Chapter Summary


Federal Rule of Civil Procedure, Rule 34 controls the right of a party to request the production of documents and electronically stored information from another party in federal district court, as well as the obligation to respond to that request. This chapter discusses the various issues involved in responding to a Rule 34 production request. It also examines requirements under Rule 34, and describes the timing and content of the response. The chapter covers the rules governing responses to Rule 34 production demands; objecting to Rule 34 requests; determining whether requested material is in a party's possession, custody, or control; and producing material for inspection pursuant to Rule 34 requests. The chapter also includes a checklist for drafting and serving responses to Rule 34 production requests, checklists for preparing objections to requests, checklists for evaluating Rule 34 requests, and a sample response and objections to request for production and inspection.

Federal Litigation Guide is the comprehensive how-to guide for federal litigation. It provides in depth, detailed discussions of virtually all procedures and practices of federal litigation. The treatise chronologically covers the litigation process from pretrial through trial and post trial. Among the topics covered are: pleadings, the mechanics of motion practice, Rule 12 motions, injunctions, sanctions, planning and preparation for discovery, interrogatories, document production, requests to admit, trial planning and preparation, trial briefs, witness exclusion, opening statements, direct and cross examination, objections, jury instructions, class actions, damages, appeals to the court of appeals, settlements, and court-sponsored alternative dispute resolution.


Federal litigation,Federal Rules of Civil Procedure,federal civil rules,Rule 34,request for production of documents,request for production of electronically stored information,responding to document requests,Rule 34 production demands,Rule 34 production requests,production of material for inspection


For other discussions related to responding to document requests, see Ch. 13, Production of Documents, Ch. 15, Management of Documents, and Ch. 20, Inspection of Land and Other Tangibles.


For expanded coverage of responding to document requests, see Moore's Federal Practice (Matthew Bender), Ch. 34, Production of Documents, Electronically Stored Information, and Things and Entry Upon Land for Inspection and Other Purposes.

See Bender's Federal Practice Forms (Matthew Bender) for a comprehensive set of civil and criminal litigation forms for practice in any federal court.
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