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LCvR 34 SERVING AND RESPONDING TO REQUESTS FOR PRODUCTION IN ELECTRONIC FORM A. Electronic Form. Any party may, pursuant to Rule 34 of the Fed. R. Civ. P., serve upon any other party requests for production in Writable Electronic Form (as defined in LCvR 33.B) and require that written responses thereto also be provided in electronic form, except that a party producing documents or electronically stored information shall produce them in the manner and form as may be permitted or required pursuant to Fed. R. Civ. P. 34(b)(2)(E). Upon request by any party, requests for production must be served upon the requesting party in Writable Electronic Form. Unless the serving party specifically requests that the written responses be provided in hard-copy form, the responding party shall provide the written responses to such requests for production in electronic form. Any party responding in electronic form to requests for production may serve such written response in a form which may not be altered.

B. Hard Copy Form. In the event that the parties elect not to use the electronic form for requests for production or written responses thereto, requests for production shall be prepared in such a fashion that sufficient space for insertion of the written responses thereto is provided after each request or sub-section thereof. The original and two (2) copies shall be served upon the party to whom such request for production is directed. The responding party shall insert written responses on the original request for production served upon him or her and shall retain the original and be the custodian of it. If there is not sufficient space on the original for insertion of written responses, the responding party may use and attach supplemental pages for the written responses. In lieu of the foregoing procedure, the responding party may retype each request with the written response to each such request appearing immediately thereafter.