skip to main content
Close Button
Last Name
First Name
Practice Area


Caitlin Bronner Featured in the NYLJ: Heeding the ‘Wake Up’ Call on Federal Rule of Civil Procedure 34


In 2015, the Federal Rules of Civil Procedure were amended to change, among other things, the procedure for responding to document requests under Rule 34(b). Effective as of Dec. 1, 2015, parties may no longer lodge general objections to document requests propounded by their adversaries but must, instead, “state with specificity the grounds for objecting to the request, including the reasons.” In addition, Rule 34(b) now requires practitioners to state in their objections whether any responsive materials are being withheld, and, by virtue of a simultaneous amendment to Rule 26, it is no longer permissible to object on the grounds that a request is not reasonably calculated to lead to the discovery of admissible evidence.

Despite the passage of more than two years since these amendments went into effect, many practitioners are still unaware of them...