Copy the name of the Asking Party, Answering Party, and Set Number from the Request for Production. (a) When an inspection, copying, testing, or sampling of documents, tangible things, places, or electronically stored information has been demanded, the party to whom the demand has been directed, and any other party or affected person, may promptly move for a protective order. (Requests for Production). 2d 165 (Fla. File Only Relevant Discovery Information A sample request for production of documents (RFP) (also called an "inspection demand" or "document request") that counsel may use in a California unlimited civil action. This involves asking the opposing party or other people to provide information that would not be publicly known or readily available to the party seeking it. A party that responds to a discovery request by simply producing electronically stored information in a form of its choice, without identifying that form in advance of the production in the response required by Rule 34(b), runs a risk that the requesting party can show that the produced form is not reasonably usable and that it is entitled to All opposition papers must be filed and served at least 9 court days before the hearing. R. 280(b) (Requests for Admission). 230), you may direct a notice or subpoena at an organization: Aug 5, 2010 · Motions to compel further responses to interrogatories, requests for productions of documents and requests for admissions require that the motion be filed within 45 days. 010), by a written request that any other party to the action admit the genuineness of specified documents, or Universal Citation: CA Civ Pro Code § 2031. This means the clerk signs and stamps the subpoena before you fill it out. ) Similar to state practice (Code of Civ. 60-226, and amendments thereto: Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2031. Type text, add images, blackout confidential details, add comments, highlights and more. copy to the Court. 010, et seq. The responding party has 30 days (33 days if you serve by In civil litigation, a request for production of documents is a formal method used by parties to obtain relevant information and evidence from each other. Mark your calendar. Aug 3, 2020 · Request for Production Rules. 290(b) , 2031. Ordinarily, your deadline to respond to such a request falls 33 days after the request was put in the mail 01. ) October 2006. This Standard Document contains integrated notes with important explanations on how to draft the caption, definitions, instructions, document requests, and signature block. Requests for Production of Documents are part of "Discovery," which is very common in court cases. The revised California Code of Civil Procedure mandates that “any documents or categories of documents furnished in compliance with a request for inspection, copying, testing, or Oct 18, 2023 · The Discovery Process in Lawsuits. 010 - General Information on Interrogatories. 210, 2031. 290(c) Delaying the filing of the motion waives a party's right to compel further responses. Bring a separate one for each person, business, or agency you want to subpoena. 090 creates a new set of rules for civil litigators in cases filed on or after January 1, 2024, which Requests for production, responses and proofs of service thereof shall not be filed unless and until there is a proceeding in which the request, response, or proof of service is at issue. State each of the facts that will prove this element. Request for Admissions: A series of statements about your case that you admit or deny. 280. Make a list in the template. The date specified for production must be at least thirty (30) days (five (5) days for unlawful detainer actions Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2025. using in your case. The aim is to gain insight into any relevant evidence that the opposing party holds. 060. You need to set your date for production at least 30 days after service of the demand ( CCP §2031. §§ 2031. CCP § 2025. (b) In the first paragraph immediately below the title of the case, there shall appear the identity of the party requesting the admissions, the set number, and the identity of the responding party. Discovery allows each side to build unduly burdensome or seeks documents protected by the attorney-client privilege). You use this if you want to ask questions that are specific to your case and are not included on the Form Interrogatory form. 28 provide written responses to plaintiff's supplemental request for production of documents. Take advantage of the Review button to analyze the form. App. 4000 Middlefield Road, Room D-1 Palo Alto, CA 94303-4739 650-494-1335 <commission@clrc. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; (5) To compel or to quash the production There are several types of document requests that can be made in California: 1. Superior Court (1983) 147 Cal. This is a general first set request for admissions that is narrowly tailored to the specific facts of the case. 300(b) (Requests for Production); CCP 2033. Use a Special Interrogatory (sometimes called a Specially Prepared Interrogatory) if you want to write the questions yourself. 4:18-1(b)(1) (renumbered eff 9/1/10). Any and all records of oral communication between RSI and UPS between March 1, 2007 and the present date that relate Apr 22, 2017 · E-Discovery UpdateThe December 2014 Case Notes discuss the following:A Tennessee federal district court decision allowing plaintiff to use predictive coding to review two million documents notwithstanding defendant’s opposition, a case management order specifying use of search terms, and initial screening with such terms; A Northern District of California order ruling that the production of Jan 1, 2023 · The court, on motion, may relieve that party from this waiver on its determination that both of the following conditions are satisfied: (1) The party has subsequently served a response that is in substantial compliance with Sections 2031. The true scope of requests for admission is provided in Civ. Timing is critical and different for various types of discovery and depends on if a response is served. Requests for production may also be served with the summons and complaint. v. It can be used in certain civil lawsuits in the Northern District Court of California. 4th 1060, 1072-1075. Any party may, by written request to any other party: 1. " Rule 34(b)(2)(B) and (C), modeled after Federal Rule 34(b)(2)(D) and (E), have been added to deal with responding to a request for production of electronically stored 60-234. See The Florida Bar, 391 So. 220 only requires 10 days notice if the notice of deposition There are also specific duration limits on depositions in federal court: “Unless otherwise stipulated or ordered by the court, a deposition is limited to 1 day of 7 hours. 300(b) and 2033. 010, to document requests included in a deposition notice pursuant to Code of Civil Procedure section 2025. 030 (c) (2) ). 710), and subject to the restrictions set forth in Chapter 5 (commencing with Section 2019. The term "communication" means the transmittal of information (in the form of facts, opinions, ideas, inquiries, or otherwise). 18(c)(1) with respect to any objection to or other failure to respond to the request or any part thereof, or any failure to permit inspection as requested. there is no limit. 3d 681 at 685 (Pre e of Service. e complaint filed on January 19, 2013. Section 2016. ” (Maldonado v. There is no specific limit on the number. If a lawsuit gets past its initial stages, the plaintiff and the defendant will go through a period of discovery. Pursuant to Virginia Supreme Court Rule 4:9, a party has 21 days to respond to By Emily S. If your case is an unlimited civil case (more than $35,000) form interrogatories are not counted against the amount of discovery you may ask. Look at the description to actually have Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2031. 230) or (3) object (C. The other side has to answer all of the requests unless they obtain a protective order. 280 (a) requires produced documents to be "identified with the specific request number to which the documents respond. notice when a request for documents is made the witness is “expected to make an inquiry of everyone who might be hold-ing responsive documents or everyone who knows where such documents might be held. Demand for Production of Documents: A series of requests to . This template was prepared by the Justice & Diversity Center, a nonprofit organization, and is not an official court form. S. Any party may obtain discovery within the scope delimited by Chapters 2 (commencing with Section 2017. 280 . List the evidence you will need to support the facts that prove this element. interrogatories, requests for production, and requests for admission. As of January 2020, the California Code of Civil Procedure now requires that “[a]ny documents or category of documents produced in response to a demand for inspection, copying, testing, or sampling shall be identified with the specific request number to which the documents respond. 34(b)(2)(B) Producing Documents and ESI : Requires that the grounds for objecting to a request be stated with specificity When the party whose documents are sought shows that the request for production is unduly burdensome or oppressive, courts have denied discovery for lack of “good cause”, although they might just as easily have based their decision on the protective provisions of existing Rule 30(b) (new Rule 26(c)). 410(a)–(b), 2025. § 2031. Direct the production, copying reproduction, photographing, testing or sampling of specified documents, objects or tangible things whenever relevant to the subject matter of the action. A. 050. (2) The party's failure to serve a timely response was the Revised: March 2017 Federal Pro Se Clinic“Incident” includes the circumstances and events surrounding the alleged wrongful conduct, injury, or other occurrences giving rise to this lawsuit as alleged i. 220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C. 050 through (2015) Leg Sess. 4. California Civil Discovery KFC 1020 . H64 Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2031. section 2031. Take a blank Deposition Subpoena for Personal Appearance and Production of Documents and Things ( form SUBP-020) to your court clerk's office. . When required in a proceeding, only that part of the request for production, response or proof of service that is in issue shall be filed. This template provides guidance only. > > Read More. In the above Oct 22, 2011 · 4 attorney answers. 010. 230, 2031. , §§ 2025. 010, subd. 050, effective January 1, 2024. 240(c)(1) and (2) and provide a privilege/redaction log. If you are having the Request for Production served by mail, you must allow an additional 5 days, so set the date least 35 days from the date you will have the Request for Production served by mail. E. (a) Any party may obtain discovery within the scope delimited by Chapter 2 (commencing with Section 2017. Sign and date. 1, 2024) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of Feb 5, 2020 · Effective January 1, 2020, discovery in California state courts follows three new rules, set out in California Code of Civil Procedure sections 2031. P. Request for Production of Documents: This type of request seeks the production of relevant documents related to the case. For each item, write “Response to Request for Production Number” followed by the FORMULATING REQUESTS FOR DOCUMENTS. (O. Even non parties can be requested to produce documents/tangible things [i] . (d) Form of production. 090] 2030. 2030. California Requests for Production of Documents and Things refer to the legal process through which one party in a lawsuit requests the other party to produce specific documents or physical items that are relevant to the case. 60-226(b), and amendments thereto: Feb 26, 2023 · There is no limit to the number of requests for production a party may serve; however, the court expects the number of requests to be proportional to the issues involved in the case and that a party will not use the number of requests to harass and burden another party. Once the documents are complete, make. However, subsection (c) of Rule 2004 does provide that Bankruptcy Rule 901610 may be used to compel the “the production of documents” in connection with an oral examination, and thus the Rule indirectly allows for interrogatories or requests for 60-234. Superior Court (2004) 122 C. If no responses at all are served, there is no time limit on when and authenticity of evidence or documents. The clerk will issue the subpoena. Serve the Requests. An unlawful detainer case is a special proceeding by a landlord to regain possession of real property from a tenant. Lockyer v. 030. Unless the parties otherwise agree, or the hearing officer otherwise orders: These potential sanctions apply to inspection demands served in written discovery pursuant to Code of Civil Procedure section 2031. 310(c) and 2032. 36 (A). ”) to place additional requirements on the production of documents during discovery. Legal Consult Recommended. See Rule 81(c), providing that these rules govern procedures after removal. 050, and 2016. § 9-11-34 (c)). C. (a) The service of a deposition notice under Section 2025. At the Law Library. The rule previously Starting from January 1, 2020, civil litigants in California are subjected to more rigorous requirements when responding to request for production of documents. G. This is a major departure from the prior rule. 010 Demand for Production and must May 6, 2018 · A demand to produce documents pursuant to California Code of Civil Procedure section 2031. Sign it in a few clicks. Requests for production often reveal crucial information that can shape the outcome of a case. You want to serve your demand at least 90 days before the trial to ensure there is enough time for documents to be produced and 2017 Instructions: Requests for Production - General 1 of 3 Instructions: Requests for Documents . Civ. or Interrogatory)Federal Pro Se Clinic Roybal Courthouse 255 East Temple Street, Suite 170 Los Angeles, CA 90012 (213) 385-2977 ext. SUMMARY OF RECOMMENDATION. Eastern Dist. A request for production of documents at deposition in California is typically initiated by serving a written notice upon the opposing party, either prior to or during the deposition. , § 2025. 090 and 2023. 010 et seq. [CCP 2030. 220, 2031. ” (Cal. within 45 days. 1, 2024) you may ask each party only 35 discovery questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of documents. Title t. Jun 29, 2011 · If you are in the Superior Court in California there is no limit under Code of Civil Procedure section 2031. 030 - Limitation on Number of Interrogatories That May Be Served. produce (or provide copies) of certain documents, pictures, receipts, letters, emails, reports, etc. ca. (a) A party requesting admissions shall number each set of requests consecutively. SERVING YOUR REQUESTSMake copies. ty to the case. (April 10, 2024) - California legislators have changed the rules of discovery in civil cases through the passage of amendments to Code of Civil Procedure sections 2016. 270 Op. (Code Civ. , § 203. A Special Interrogatory doesn't use a specific court form. Subdivision (a). In a limited civil case (cases demanding less than $25,000, or $35,000 if filed after Jan. ” (Rule 30(d)(1). In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. t. ” The Ohio Rule Below is a sample request for production of documents in a motor vehicle crash case that later settled for $750,000. 300(c), 2031. 280(a). In previous years, C. Jul 1, 2005 · (c) The number of requests for admission of the genuineness of documents is not limited except as justice requires to protect the responding party from unwarranted annoyance, embarrassment, oppression, or undue burden and expense. 010), and subject to the restrictions set forth in Chapter 5 (commencing with Section 2019. (2) Document. Oct 11, 2022 · On each page, write in the page number and the total. In responding to Requests for Production of documents you have three response choices (1) agree to produce (C. 240). If the deponent is a party (or an officer, director, managing agent or employee of a party), a deposition notice that includes a request for production of documents at the time of the deposition is sufficient to compel their production. This request is typically sent by the injured party's attorney to the opposing party, such as the defendant or their insurance company, to gather documents Jan 23, 2024 · A motion to compel is a request to the court to issue an order to compel the other party to answer a question or to produce a document or object. Requests for production is a discovery device by which each party can request documents and other evidence from other parties and can compel the production of evidence by using a subpoena. The notice of deposition for oral examination may be accompanied by a request for production of documents and tangible things. Each document that you file must be “served” on each other party, usually by sending it in the mail. Posted in Motion to Compel Further Responses. (a) In general. DOCUMENT REQUESTS. (Code. CCP § 2033. However, if you file an affidavit of necessity, showing why you should be permitted to exceed the Rule of 35, you can ask more than 35 questions, document production, admissions, etc. A party demanding inspection, copying, testing, or sampling of electronically stored information may specify the form or forms in which each type of electronically stored information is to be produced. Request for Production at Oral Examination . State each element of your claim or defense. 280 allowed litigants to choose how they produced documents in response to a request for production. J. In addition to complying with the provisions of Rules 26, 34 and 45, Federal Rules of Civil Procedure, a request for documents, whether a request for production or a subpoena duces tecum, should be clear, concise, and reasonably particularized. Draw your signature, type it, upload its image, or use your mobile device as a signature pad. Discovery of documents, electronically stored information, and property (a) Scope. (a) In addition to the demands for inspection, copying, testing, or sampling permitted by this chapter, a party may propound a supplemental demand to inspect, copy, test, or sample any later acquired or discovered documents, tangible things, land or other Apr 10, 2024 · San Diego, Calif. A party may serve on any other party a request within the scope of K. rtificate are serv. Any and all written correspondence between RSI and United Parcel Service (UPS) between March 1, 2007 and the present date that relate directly to the April 1, 2007 contract between said parties for 2,000 GMUs. If your case is a limited civil case ($35,000 or less) you can request up to a total of 35 combined request for admissions , form interrogatories , special interrogatories, and requests for production . Jan 23, 2024 · The request must be specific so that your spouse can tell exactly which documents or items to produce. 440(a). A party may serve on any other party a request within the scope of subsection (b) of K. Ca. Near the end of discovery, it is wise to send out a more case-specific set to tie up any loose ends and follow-up on May 17, 2022 · When a party responds to a Request for Production of documents the response must comply with C. 040 - Declaration For Additional Special Interrogatories, Option of Seeking Protective Order Jan 24, 2020 · The California Code of Civil Procedure now requires “[a]ny documents or category of documents produced in response to a demand for inspection, copying, testing, or sampling shall be identified with the specific request number to which the documents respond. The term "document" is defined to be synonymous in meaning and equal in scope to the The party submitting the request may move for an order under § 26. Any party may serve one or more requests to any other party (1) as to items that are in the possession, custody, or control of the party upon whom the request is served, to produce and permit the party making the There are different types of limits on requests for production of documents in California, including: 1. Follow the instructions on the Certificate of Service. Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2033. Sep 26, 2011 · Virginia is the same way, with specifically limited interrogatories, but no limit for requests for production of documents. ” Cal. 090. (a) In addition to the demands for inspection, copying, testing, or sampling permitted by this chapter, a party may propound a supplemental demand to inspect, copy, test, or sample any later acquired or discovered documents, tangible things, land or other property, or electronically Depositions, interrogatories, requests for documents and requests for admission and their responses must not be filed until they are used in the proceeding or the court orders filing. FRCP 5 (d) (amended eff 12/1/18). ) The request to produce is similar in nature to a §2031. CCP § 1005 (b) (amended eff 1/1/23). Any party may serve on any other party a request: (1) To produce and permit the party making the request, or someone acting on his behalf, to inspect and copy any designated documents (including writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained), or to inspect and copy, test, or sample any tangible things that are in The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; (5) To compel or to quash the production California Request for Production of Documents — Personal Injury is a legal document used in the state of California to obtain relevant information and evidence in a personal injury case. As originally adopted, Rule 34 focused on A request for production (RFP) is an eDiscovery process used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. Documents relating to the issues in the case can be requested to be produced. The case of Vidal Sassoon, Inc. 480(a). , Lauer v. , Lawless, Lawless & McGrath. App. May 8, 2020 · Request for Production Rules. Committee Notes on Rules—2006 Amendment. Pro. ) California Code of Civil Procedure - Interrogatories Table of Contents Propounding Interrogatories [CCP 2030. 010 - 2030. 4th 1390, 1396. 2023 California Code Code of Civil Procedure - CCP PART 4 - MISCELLANEOUS PROVISIONS TITLE 4 - CIVIL DISCOVERY ACT CHAPTER 14 - Inspection, Copying, Testing, Sampling, and Production of Documents, Electronically Stored Information, Tangible Things, Land, and Other Property ARTICLE 1 - Inspection Demand Section 2031. Jan 1, 2012 · Civil Subpoena (Duces Tecum) for Personal Appearance and Production of Documents, Electronically Stored Information, and Things at Trial or Hearing and Declaration (SUBP-002) Orders a person who is not a party to a case to appear and testify at and bring specific documents or things to a trial or court hearing. g. Keep this limit in mind when writing your requests, to Reduces the presumptive limit on the number of depositions from 10 to 5, and the presumptive duration from 7 hours to 6. (a) Any party may obtain discovery within the scope delimited by Chapters 2 (commencing with Section 2017. tion. FAILURE TO RESPOND There is no time limit on bringing the motion to compel the response to the Interrogatories, or the request for production of documents, or have the admissions be deemed admitted. California Law Revision Commission. Edit your sample request for production of documents california online. Next, you can down load the California Request for Production of Documents template. Discovery disputes over documents usually revolve around the privilege of the particular documents, or the overall burden of producing them, not the number of requests. 290(b) (Interrogatories); CCP 2031. LR Jan 11, 2013 · Requests for Production of Documents Rule 2-422. N. Dec 4, 2018 · The Georgia Civil Practice Act allows parties to a lawsuit to serve requests for production of documents on nonparties as part of the process of gathering information relevant to the subject matter of the case. ext, state your Requests for Production. ne copy for each pa. CCP §§ 2030. 010) and 3 (commencing with Section 2017. o People ex rel. . Mar 21, 2013 · You can combine form and special Interrogatories, Requests for Admission, Production of Documents, etc as long as they do not exceed a total of 35. pp. gov>. (c). > > Read More Before you start. 2. Superior Court (2002) 94 Cal. 010), by inspecting documents, tangible things, and land or other property that are in the possession In California, the limit for the number of requests or categories of documents within a request for production can vary depending on the type of case and certain court rules. , § 2031. 210 – 240. 280, 2023. For example, a request for "each and every document supporting Mar 16, 2023 · The new law, which took effect January 1, 2020, amended California’s Code of Civil Procedure (“C. Timing of Motion to Compel. The responding party has 30 days (33 days if you serve by mail) to send you a written. Numerical Limit: In California, unless otherwise stipulated by the court, parties are generally limited to a maximum of 35 specially prepared interrogatories, 35 requests for admissions, and 35 requests for production of documents in total. 02. 1980). According to the Rule, requests for admission can relate to “statements or opinions of fact or of the appli-cation of law to fact, including the genuineness of any documents described in the request. Proc. 480(b) (amended eff 1/1/13) Dec 11, 2020 · The plaintiff will then use the requests for production of documents to request copies of all policies of insurance that were identified in that interrogatory answer. Prepare the Certificate of Service. §2031. 33 : Interrogatories : Reduces the presumptive limit on the number of interrogatories from 25 to 15. The time must be during regular business hours and at least 30 days from the date you are having your Request for Production personally served. documents. (§ 2025. ) Your client may attend the deposition and refuse to comply with all or some of the document requests, placing the burden on noticing counsel to move to compel production. 4:14-2(d). requires a written response and production of documents in 30 days, whereas a request to produce documents at a deposition pursuant to California Code of Civil Procedure section 2025. If a party asserts a privilege for any document and either withholds the document or redacts the document, then the party must comply with C. 240 is effective to require any deponent who is a party to the action or an officer, director, managing agent, or employee of a party to attend and to testify, as well as to produce any document, electronically stored When a case with outstanding requests for production is removed to federal court, the time for response would be measured from the date of the parties’ meeting. Aug 4, 2009 · Timing: Responses to requests for production are due within thirty (30) days (five (5) days in unlawful detainer actions) if the requests were personally served, thirty-five (35) days if the requests were served by mail, and thirty (30) days plus two (2) court days if the requests were served by express mail or facsimile or electronically. ) The testimony of the chosen PMQ is then the “voice” of the deponent, in This is a multi-state form covering the subject matter of the title. Be sure the Requests and. Whether on a form or not, the Request for Production will have a numbered list of documents or items they want you to produce. Calculating the Deadline. Sep 24, 2015 · The following definitions apply to all discovery requests, unless otherwise ordered by the court: (1) Communication. ) Where a party finds the response to a request for production inadequate and seeks to compel further responses to a request for production of documents, it must fil. Both parties have the ability to serve requests for production of documents to the other party. You can propound as many demands for production of documents as are reasonably necessary but the demands must be reasonably calculated to lead to the discovery of admissible evidence. that you intend (or possibly intend) on . 2031. First, when responding to requests for production, the produced documents must identify the specific request to which they respond. Unless you provide an accounts and wish to begin using US Legal Forms, adopt these measures: Discover the kind you want and ensure it is to the proper city/area. Production of documents, electronically stored information, tangible things and entry onto land for inspection and other purposes. A motion to compel answers to deposition questions or the production of documents or things must be made no later than 60 days after the completion of the deposition record. 03. Added by Stats 2004 ch 182 (AB 3081),s 23, eff. New Rules. CCP § 12. It may include contracts, agreements, emails, invoices, financial records, photographs, videos, or any other tangible items that may be relevant. McGrath, Esq. serve a copy of the request upon persons not parties upon all other parties to the litigation. 240, and 2031. 60 Days After Completion of Deposition Record. Generally, parties are allowed to serve up to 35 requests for production of documents in unlimited civil cases, while in limited civil cases, the limit is often reduced to (a) Scope. Code § 2033. No Time Limit for No Response or Unverified Responses – An unverified response is no response at all, and there is no time limit to move to compel. At about the time the Committee was involved in its study of Rule 34, the Supreme Court of Florida promulgated some new rules governing production of documents and things without deposition. The rules on requests for production of documents and tangible things start at Code of Civil Procedure section 2031. The time in which any act provided by law is to be done is computed by excluding the first day, and including the last, unless the last day is a holiday, and then it is also excluded. California law places strict limits on the number of discovery requests a party can make. See CCP §§2030. 210, and to nonparty discovery, including requests for documents in business record and deposition subpoenas Introduction to Discovery – Part 9: Responding to Requests for Production Part 9 of this video series from the Sacramento County Public Law Library’s Civil Self-Help Center will help you understand what Requests for Production are, and how to respond to these types of requests. 7/1/2005. ) No Time Limit for No Response or Unverified Responses – An unverified response is no response at all, and there is no time limit to move to compel. 010 ), by inspecting, copying, testing, or sampling documents, tangible things, land or CCP § 2031. 020 - Timing For Serving Interrogatories. the m. Language has been added to Rule 34(b)(1) to the effect that a request for production "may specify the form in which electronically stored information is to be produced. uy ut kf kn hp du ei qe rc mn