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0 tracked cards Civil Procedure

A plaintiff served Rule 34 requests for emails, spreadsheets, and inspection of a machine involved in an accident. The defendant responded to several requests by stating only, "Objection, overbroad and burdensome," and did not say whether it was withholding responsive materials. For emails, the plaintiff requested native files with metadata. The defendant produced searchable PDFs without explaining why native files were unavailable or unduly burdensome.
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A responding party must respond to each item or category, state with specificity the grounds for any objection, and state whether responsive materials are being withheld on the basis of the objection. Rule 34 applies only to paper documents and tangible things, not electronically stored information. A requesting party may enter the responding party's land without describing the property or the requested inspection. A responding party may make a general objection that a document request is burdensome and need not say whether any documents are being withheld.

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