Five years ago, the Federal Rules of Civil Procedure underwent its most significant overhaul in decades. This revamp included amendments to Rule 34, which governs production of documents in litigation. Effective Dec. 1, 2015, Rule 34(b)(2)(B) requires litigants to “state with specificity the grounds for objecting to the [document] request, including the reasons” and Rule 34(b)(2)C) mandates that “[a]n objection must state whether any responsive materials are being withheld on the basis of that objection.”

Further, litigants must specify the timing of production. Per the Advisory Committees’ note, these changes were intended to “reduc[e] the potential to impose unreasonable burdens by objections to requests to produce” as well as “end the confusion that frequently arises when a producing party states several objections and still produces information.”