Rule 2-422.Discovery of documents, electronically stored information, and property — From party

Rule 2-422 is Maryland's document-request rule. Any party can serve a request asking another party to produce, and let the requester inspect, copy, test, or sample documents and electronically stored information within that party's possession, custody, or control. The same request can reach tangible things and, separately, can ask for entry onto land or property the other party possesses or controls, so the requester can inspect, measure, survey, photograph, test, or sample it. Everything demanded has to fall within the scope of discovery set out in Rule 2-402 (a), and the request itself must describe each item or category with reasonable particularity and propose a reasonable time, place, and manner for the inspection. A request can also specify the form electronic information should come in.

The party on the receiving end has 30 days from service, or 15 days from when its own initial pleading or motion is due, whichever is later, to respond in writing. For each item or category, the response has to say whether inspection will be permitted, whether the request is refused, or whether the requested electronic format is refused, with full grounds stated for any refusal. When producing, a party must either keep documents organized as they're kept in the ordinary course of business or label them to match the request's categories, and it must produce electronically stored information in the form requested (or, absent a specified form, in the form it's ordinarily kept or another reasonably usable form). No one has to hand over the same electronic information twice in different formats. Requests aimed at land or property owned by a nonparty, or discovery reaching outside Maryland under the interstate discovery statute without an accompanying deposition, run instead through Rule 2-422.1.