Just over a year ago, I authored a
Product Liability Advocate blog entry and a Law360 article explaining appropriate
methods for asserting objections under Federal Rule of Civil
Procedure 34, as amended on December 1, 2015. Last week, Judge
Andrew J. Peck, U.S.M.J. of the Southern District of New York,
issued an order that in his court any discovery objections that
fail to comply with Rule 34 of the Federal Rules of Civil
Procedure, as amended on December 1, 2015, will be deemed
waived:
The December 1, 2015 amendments to
the Federal Rules of Civil Procedure are now 15 months old. It is
time for all counsel to learn the now-current Rules and update
their "form" files. From now on in cases before this
Court, any discovery response that does not comply with
Rule 34's requirement to state objections with specificity (and
to clearly indicate whether responsive material is being withheld
on the basis of objection) will be deemed a waiver of all
objections (except as to
