[Session 6] Crafting eDiscovery Requests with Specificity

Despite Fed. R. Civ. P. 34(b)’s “reasonable particularity” language, and the other rules and caselaw that underscore the mandate for specificity, vague and overbroad discovery requests have continued, clogging the courts and increasing litigation costs. When vague discovery requests are challenged, the requesting party often is simply provided a “do-over” opportunity to refine the original requests or propound new requests, leaving little incentive to follow the mandates of Rule 34. Join this new brainstorming group as we dialogue about: (i) how parties should approach drafting and propounding requests pursuant to Rules 34(a) and (b); (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; and (iv) how courts enforce the scope and “reasonable particularity” requirements of Rules 34(a) and (b), and the proper remedies for failing to serve specific discovery requests.