[Session 1] Drafting Team Update: Sweating the Details—Drafting ESI Requests with Specificity

While the 2015 Amendments did not amend Rule 34(b)(1), the 2015 Amendments to Rule 34(b)(2) have highlighted the fact that many practitioners do not craft document requests with reasonable particularity as required by Rule 34(b)(1). Drafting discovery requests with reasonable particularity has been a continuous challenge for practitioners for a variety of reasons, and this panel seeks to address those challenges and provide practical solutions to promote compliance. As a follow-up to the “Crafting eDiscovery Requests with Specificity Panel” from the 2019 Midyear Meeting, this session will discuss the drafting team’s progress relating to its charge of drafting a primer to address preparation of discovery requests in compliance with Rule 34(b)(1).