Maryland Circuit Court Discovery - 3. Requests for Production

Request for Production – Maryland Rule 2-422

You may ask the opposing party to produce documents, tangible things, and electronically-stored information (“ESI”), and to permit you to enter land or property. See Maryland Rule 2-422(a). The Rules do not set a limit on the number of documents you may request. However, you should be reasonable in your requests. Each request should describe the individual item or category. If you would like to inspect a tangible item or examine land or property, you should specify a reasonable time, place, and manner for inspecting.

Once you are served a request for production, you are required to submit a written response within the time limit.  The time limit will be the later of two dates.  The first date is: 30 days after you were served with the request for production.  The second date is: 15 days after your initial pleading or motion is required.  You have until the later of these two dates to submit your written response to the request for production.  If you have objections to a request, you need to respond and explain the reason for your objection. Read the Rule: Maryland Rule 2-422(c)

It has become increasingly popular for parties to ask each other for ESI. Consult Maryland Rule 2-422(d). If your opposing party asks for ESI, you must produce them either “as they are kept in the usual course of business or organize and label them to correspond with the categories in the request.”  See Maryland Rule 2-422(d)(1)(A). If your opponent asks you to produce the ESI in a specific form, you should produce it that way. If the request does not specify, you should produce the documents how they are normally maintained or in a format that is reasonably usable.

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