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Judge Peck has issued a second wake-up call type of opinion in Fischer v. Forrest, _ F. Supp. 3rd _, 2017 WL 773694 (S.D.N.Y. Feb. 28, 2017). Judge Peck’s first wake-up call in 2009 had to do with the basics of keyword search – William A. Gross Construction Associates, Inc. v. American Manufacturers Mutual Insurance Co., 256 F.R.D. 134 (S.D.N.Y. 2009), which is still one of my favorite all time e-discovery opinions. His second wake-up call has to do with the basics of Rule 34, specifically subsections (b)(2)(B) and (b)(2)(C):
It is time, once again, to issue a discovery wake-up call to the Bar in this District:1/ the Federal Rules of Civil Procedure were amended effective December 1, 2015, and one change that affects the daily work of every litigator is to Rule 34. Specifically (and I use that term advisedly), responses to discovery requests must:
* State grounds for objections with specificity;
* An objection must state whether any responsive materials are being withheld on the basis of that objection; and
* Specify the time for production and, if a rolling production, when production will begin and when it will be concluded.
Most lawyers who have not changed their “form file” violate one or more (and often all three) of these changes.
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