Rule 1.512.Production of documents, electronically stored information, and things; entry upon land for inspection and other purposes

Rule 1.512 covers three distinct kinds of requests. A party can ask to inspect, copy, test, or sample designated documents or electronically stored information — a category defined broadly to include writings, drawings, graphs, charts, photographs, sound recordings, images, and other data stored in any medium, translated into a usable form if necessary. Separately, a party can request inspection, copying, testing, or sampling of tangible things within the scope of Rule 1.503, or ask to enter land or other property the other side possesses or controls, to inspect, measure, survey, photograph, test, or sample it or anything on it. Each request must identify items or categories with reasonable particularity and specify a reasonable time, place, and manner for the inspection; a request aimed at electronically stored information may also specify the form the responding party should use to produce it.

A response is due within 30 days unless the court adjusts that period. For each item or category, the response must state that inspection will be permitted as requested, or object with specificity and reasons — and if the responding party chooses to produce copies instead of allowing inspection, production must be completed by the inspection date stated in the request or a later reasonable time stated in the response. A ground left out of a timely objection is waived unless the court excuses it for good cause, and a party may respond in part subject to an objection without losing that objection, so long as it specifies what has been withheld — again subject to the duty to supplement under Rule 1.503(4). Objecting to only part of a request requires identifying that part while still permitting inspection of the rest. On the electronic side, a responding party may object to a requested form for producing electronically stored information, and if it objects or no form was specified, it must state the form or forms it plans to use.

Absent an agreement or court order on the mechanics, a party producing documents must produce them as kept in the ordinary course of business or organize and label them to match the request's categories. Electronically stored information not addressed by a specified form must be produced in the form it is ordinarily kept or in a reasonably usable form, and a party never has to produce the same electronically stored information in more than one form. Rule 1.512(2)(c) lets the requesting party move to compel under Rule 1.517 over any objection or failure to respond or permit inspection, and Rule 1.512(3) allows the supreme court to approve pattern requests for production, mirroring the pattern-interrogatory option in Rule 1.509(4).