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Rule 34 (b) (2) (b) is further amended to reflect the common practice of producing copies of documents or electronically stored information rather than simply permitting inspection

The response to the request must state that copies will be produced. When incorporating the requirements of amended rule 34, a response to document demands should include three sections (1) identification of responsive documents, (2) objections and (3) an. Producing documents, electronically stored information, and

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