Rule 34.Production of Documents, Electronically Stored Information, and Things, and Entry Upon Land for Inspection and Other Purposes.

A party may ask another party to produce and permit inspection, copying, testing, or sampling of documents and electronically stored information — including writings, photographs, sound recordings, and any other data from which information can be retrieved, converted to a usable form if necessary — or of tangible things within the scope of discovery, or to allow entry onto land the responding party controls for inspection, measuring, surveying, photographing, testing, or sampling. The request must describe each item or category with reasonable particularity and propose a reasonable time, place, and manner for the inspection, and it may specify the form electronically stored information should take. A request can't be served before discovery normally opens.

The responding party has 30 days to serve a written response stating, item by item or category by category, whether inspection will be permitted, and must state its reasons for any objection, including an objection to the requested electronic format; if only part of an item or category is objectionable, the response must say so and allow inspection of the rest. Absent an agreement or court order otherwise, a party producing documents must produce them as kept in the ordinary course of business or organize them to match the request's categories, must produce electronically stored information in the form it's ordinarily kept (or another reasonably usable form if none was specified), and never has to produce the same electronic information in more than one usable form. The rule doesn't stop a party from bringing a separate action against a non-party to get documents produced or to gain entry onto land.