What is the procedure for replying to a request for production and inspection? What rules apply?

Question

Quizplus · Accepted Answer

The Answer is Before drafting the response, review each item of the request once more. For each item of the request, outline:
• What documents or information responsive to that item, if any, were located in the search of information
• Any objection and the reasons for the objection (failure to object may waive the objection)
• In what form or forms the opponent wants the information produced and in what form or forms it is best for your client to produce the item
• What differences or concerns need to be worked out with the other party prior to seeking a protective order
• What process is best for the client and the opponent for delivering the information or conducting any inspection, copying, testing, or sampling of the information

What Is the Procedure for Replying to a Request for Production