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Rule 34.Production of Documents and Things and Entry Upon Land for Inspection and Other Purposes

Part V. Depositions and Discovery · Last verified September 4, 2026

In one sentenceRule 34 governs requests to produce documents and things and to enter land, with 30 days to respond and 45 for a defendant served with the summons and complaint.

Full Text of Rule 34

Text sizeJump to: (a) (b) (c)

(a) Scope. Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on his behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phono-records, and other data compilations from which information can be obtained, translated, if necessary, by the respondent through detection devices into reasonably usable form), or to inspect and copy, test, or sample any tangible things which constitute or contain matters within the scope of Rule 26(b) and which are in the possession, custody or control of the party upon whom the request is served; or (2) to permit entry upon designated land or other property in the possession or control of the party upon whom the request is served for the purpose of inspection and measuring, surveying, photographing, testing or sampling the property or any designated object or operation thereon, within the scope of Rule 26(b).
(b) Procedure. The request may, without leave of court, be served upon the plaintiff after commencement of the action and upon any other party with or after service of the summons and complaint upon that party. The request shall set forth the items to be inspected either by individual item or by category, and describe each item and category with reasonable particularity. The request shall specify a reasonable time, place, and manner of making the inspection and performing the related acts. The party upon whom the request is served shall serve a written response within 30 days after the service of the request, except that a defendant may serve a response within 45 days after service of the summons and complaint upon that defendant. The court may allow a shorter or longer time. The response shall state, with respect to each item or category, that inspection and related activities will be permitted as requested, unless the request is objected to, in which event the reasons for objection shall be stated. If objection is made to part of an item or category, the part shall be specified. The party submitting the request may move for an order under Rule 37(a) with respect to any objection to or other failure to respond to the request or any part thereof, or any failure to permit inspection as requested. A party who produces documents for inspection shall produce them as they are kept in the usual course of business or shall organize and label them to correspond with the categories in the request.
(c) Persons Not Parties. This rule does not preclude an independent action against a person not a party for production of documents and things and permission to enter upon land.
End

Plain-English Summary

Rule 34 has two operative subsections and a saving clause. It is shorter than its civil counterpart, which carries a detailed electronic-discovery apparatus this ruleset does not.

What can be requested

Any party may serve a request to inspect and copy designated documents — the rule's parenthetical reaches writings, drawings, graphs, charts, photographs, phono-records and other data compilations from which information can be obtained, translated if necessary through detection devices into reasonably usable form — or to inspect, copy, test or sample tangible things. Both are limited to matters within the scope of Rule 26(b) that are in the possession, custody or control of the party served.

The second branch is entry upon land or other property in the party's possession or control, for inspection, measuring, surveying, photographing, testing or sampling the property or any designated object or operation on it.

Procedure

No leave of court is needed. The request may be served on the plaintiff after commencement, and on any other party with or after service of the summons and complaint.

The request must set out the items by individual item or by category and describe each with reasonable particularity, and must specify a reasonable time, place and manner.

The response is due within 30 days — or a defendant may respond within 45 days after service of the summons and complaint. It must state as to each item or category that inspection will be permitted as requested, or state the reasons for objection; where the objection is to part of an item or category, that part must be specified.

The requesting party may move under Rule 37(a) on any objection, failure to respond, or failure to permit inspection.

How documents come

The last sentence of (b) is the one that decides what a production actually looks like: a party producing documents must produce them as they are kept in the usual course of business, or organize and label them to correspond with the categories in the request. There is no third option.

Subsection (c) preserves an independent action against a non-party for production and entry — this rule reaches parties, and Rule 45 is how a non-party is reached in a pending case.

Frequently Asked Questions

How long do I have to respond to a request for production?

30 days after service of the request. A defendant may serve a response within 45 days after service of the summons and complaint. The court may allow a shorter or longer time.

How do documents have to be produced?

Rule 34(b) requires a party who produces documents for inspection to produce them as they are kept in the usual course of business, or to organize and label them to correspond with the categories in the request.

How specific does a document request have to be?

Rule 34(b) requires the request to set forth the items either by individual item or by category, and to describe each item and category with reasonable particularity. It must also specify a reasonable time, place and manner for the inspection.

Can I get documents from someone who is not a party?

Not under Rule 34, which reaches parties. Rule 34(c) preserves an independent action against a non-party for production of documents and things and permission to enter upon land, and Rule 45 provides the subpoena route in a pending case.

Can I inspect property?

Rule 34(a)(2) allows a request to permit entry upon designated land or other property in the possession or control of the party served, for inspection and measuring, surveying, photographing, testing or sampling the property or any designated object or operation on it, within the scope of Rule 26(b).

Source & verification. Rule text reproduced verbatim from the Massachusetts Rules of Domestic Relations Procedure as published by the Massachusetts Trial Court Law Libraries, current through amendments effective May 1, 2010. Promulgated by the Supreme Judicial Court of Massachusetts. Last verified September 4, 2026. · Official text
Also known as: request for productionRFPproduction of documentsentry upon landdocument requestsinspection