Proportionality and Labeling ESI Productions
Joshua Gilliland
JANUARY 30, 2016
The Plaintiff rightly objected to these requests, but made only improper boilerplate objections. The new Rule 34(b)(2)(B)-(C) requires parties to object with “specificity” and “an objection must state whether any responsive materials are being withheld on the basis of the objection.”
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