Fed. R. Civ. P. 34 — Producing Documents, Electronically Stored Information, and Tangible Things
Last verified: May 19, 2026 · U.S. Courts — FRCP.
Plain English
Rule 34 is how you get documents and electronically stored information — ESI — from the other side. You serve a request describing the items with reasonable particularity. The responding party has 30 days to respond, and the 2015 amendments tightened the response rules: you must state whether you are withholding anything based on an objection, and objections must be specific. “Vague, overbroad, and unduly burdensome” with no detail no longer survives.
Key Cases & Authority
- Zubulake v. UBS Warburg LLC, 217 F.R.D. 309 (S.D.N.Y. 2003) — Landmark ESI production and cost-shifting framework.
- Da Silva Moore v. Publicis Groupe, 287 F.R.D. 182 (S.D.N.Y. 2012) — First federal opinion approving technology-assisted review (predictive coding) for Rule 34 production.
- 2015 Amendments — Required specific objections and a statement whether responsive materials are being withheld; ended the era of boilerplate objections.
Florida Parallel
Fla. R. Civ. P. 1.350 — Florida’s production rule is parallel; Florida ESI practice is less developed than federal Rule 34 / 37(e).
About this rule walkthrough
Part of The Federal Rule Book, hosted by John M. Phillips — Board Certified Civil Trial Lawyer, Court TV analyst, admitted in 8 states + 9 federal districts + SCOTUS.
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Educational only — not legal advice.
Rule Text (verbatim from the Florida Supreme Court)
(a) A party may serve on any other party a request to produce and permit inspection of documents, electronically stored information, or tangible things in the responding party’s possession, custody, or control, or to permit entry onto land.
(b)(2) The party to whom the request is directed must respond in writing within 30 days. For each item, the response must either state that inspection will be permitted or state with specificity the grounds for objecting, including the reasons. An objection must state whether any responsive materials are being withheld on the basis of that objection.
Educational reference. This page summarizes a Federal Rule of Civil Procedure for educational purposes. It is not legal advice. Federal procedural rules can change — always verify the current text at uscourts.gov before relying on this summary in any case.
What this rule means in plain English
Rule 34 is how you get documents and ESI from the other side. Serve a request describing items with reasonable particularity; 30 days to respond. The 2015 amendments require specific objections and a statement whether materials are being withheld — ending boilerplate objections.