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Rule 34 provides that ?[i]f a request does not specify a form for producing electronically stored information, a party must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form? and ?[a] party need not produce the same [ESI] in more than one form.? Id. at *3 (quoting Fed.

Early Rule 34 requests may also allow parties to issue more-detailed litigation holds. Often there is a fundamental disconnect between what information one party believes should be preserved and what the other can foresee as relevant. Early Rule 34 requests provide a preview that could bridge this disconnect.

The rule provides that a request for inspection shall set forth the items to be inspected either by item or category, describing each with reasonable particularity, and shall specify a reasonable time, place, and manner of making the inspection.

The Federal Rules of Civil Procedure have several important provisions about production format. Rule 26 requires the parties to meet and confer about form of production in connection with the discovery plan. Rule 34 addresses content and timing of production format requests and objections.

Rule 34 of the Federal Rules of Civil Procedure provides for discovery and inspection of documents and things in the course of developing a case for trial. Subsection (b)(1)(A) states that the request must ?describe with reasonable particularity each item or category of items to be inspected.? See Fed. R. Civ.