Draft in progress: Rule 34 Specificity of Requests

The Drafting Team is tasked with drafting a Commentary or Primer that addresses: (i) how parties should approach drafting and propounding relevant and proportional discovery requests with specificity; (ii) how discovery can benefit from requests for relevant and proportional information that describe with reasonable particularity the information being sought; (iii) what “reasonable particularity” means and how to employ it, in the context of requests for relevant and proportional information; (iv) how courts enforce the scope and “reasonable particularity” requirements of Rules 26(b)(1), 34(a) and (b)(1); and (v) the proper remedies for failing to serve relevant, proportional, and specific discovery requests.