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Discovery (R. 37 - FAIL TO DISCLOSE ((a) MOTION TO COMPEL…

- - - - (A) describe with reasonable particularity
      - (B) specify time
      - (C) form of production
    - - (A) TIME TO RESPOND - 30 days
      - (B) RESPONDING TO EACH ITEM - yes or no, with specific reasons for objecting to the request
      - (C) OBJECTIONS - "An objection must state whether any responsive materials are being withheld on the basis of that objection. An objection to part of a request must specify the part and permit inspection of the rest."
      - (D) RESPONDING TO RFP OF ELECTRONICALLY STORED INFORMATION
      - (E) PRODUCING DOCS/ELECTRONIC INFORMATION - produce documents as requested or in form kept in usual course of business