Local Rule Rule 34.1: PRODUCTION OF DOCUMENTS AND THINGS
D. Wyo. — Civil rule
Rule 34.1 PRODUCTION OF DOCUMENTS AND THINGS
(a) Service of Requests for Documents. Attorneys requesting documents pursuant to Fed. R. Civ. P. 34 and 45 shall have reviewed the request or subpoena to ascertain that it is specifically applicable to the facts and contentions of the particular case. A form request or subpoena which is not specifically directed to the facts and contentions of the particular case is prohibited.
(b) Reasonable Request. A request for production or subpoena duces tecum shall be read reasonably, recognizing that the attorney serving it generally does not have knowledge of the documents being sought and the attorney receiving the request or subpoena generally has such knowledge or can obtain it from the client.
(c) Claiming Privilege or Protecting Trial Preparation Materials ("Privilege Log"). In addition to those requirements under Fed. R. Civ. P. 26(b)(5)(A), a party asserting a privilege or protection from the production of a document shall furnish all parties the following information:
(1) the type of document, e.g., letter or memorandum;
(2) the general subject matter of the document;
(3) the date of the document;
(4) the author, addressee and all other recipients of the document, their titles, positions and specific job-related duties, and the relationship of the author and all recipients to one another;
(5) the specific objection or privilege asserted and an explanation of how it applies;
(6) such other information sufficient to identify the document for a subpoena duces tecum.
(d) Oral Communications. A party asserting a privilege or qualified immunity to the disclosure of oral communications shall furnish the following information:
(1) the name of the person making the communication; the name of all persons present when the communication was made, their titles, positions and specific job-related duties, and the relationship of all people present to one another;
(2) The date and place of communication; and
(3) the general subject matter of the communication.