34.01 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 the requesting party's behalf, to inspect, copy, test or sample any designated documents or electronically stored information (including writings, drawings, graphs, charts, photographs, sound recordings, images, phonorecords, and other data and data compilations stored in any medium from which information can be obtained either directly or, if necessary, after translation by the respondent [though] into a reasonably usable form), or to inspect and copy, test, or sample any designated tangible things which constitute or contain matters within the scope of Rule 26.02 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 26.02.
Rule 34.Production of Documents and Things and Entry Upon Land for Inspection and Other Purposes
Last amended July 1, 2009 · Last verified July 2, 2026
In one sentenceRule 34 lets any party serve on any other party a request to produce, inspect, copy, test, or sample documents, electronically stored information, or tangible things, or to enter designated land for inspection and testing, requiring a written response within 30 or 45 days that states with specificity the grounds for any objection and whether responsive material is being withheld.
Full Text of Rule 34
34.02 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 request may specify the form or forms in which the electronically stored information is to be produced. 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, including an objection to the requested form or forms for producing electronically stored information, stating with specificity the grounds and reasons for objecting to the request. If objection is made to part of an item or category, the part shall be specified. An objection must state whether any responsive materials are being withheld on the basis of that objection. If objection is made to the requested form or forms for producing electronically stored information-or if no form was specified in the request-the responding party must state the form or forms it intends to use. Unless the parties otherwise agree, or the court otherwise orders:
1 The party submitting the request may move for an order under Rule 37.01 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.
2 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.
3 If a request does not specify the form or forms for producing electronically stored information, a responding party must produce the information in a form or forms in which it is ordinarily maintained or in a form or forms that are reasonably usable; and
4 A party need not produce the same electronically stored information in more than one form.
Advisory Commission Comments
Advisory Commission Comments [2009].
New Rule 34.03 replaces the earlier version, which mentioned an independent action for production or entry. The subpoena duces tecum procedure in Rule 45 is more efficient.
Amendment History
- As amended July 1, 1979.
- and by order filed January 8, 2009, effective July 1, 2009.
Plain-English Summary
Rule 34.01 lets any party serve on any other party a request to produce and permit inspection, copying, testing, or sampling of designated documents or electronically stored information — defined broadly to include writings, drawings, photographs, sound recordings, and other data compilations stored in any medium from which information can be retrieved — or of any designated tangible things within the scope of Rule 26.02 that are in the responding party's possession, custody, or control. The rule also lets a party request entry onto designated land or property to inspect, measure, survey, photograph, test, or sample it or anything on it.
Rule 34.02 lets a request be served, without needing the court's permission, on the plaintiff once the action commences and on any other party with or after service of the summons and complaint. The request must describe each item or category with reasonable particularity and specify a reasonable time, place, and manner for the inspection, and it may specify the form in which electronically stored information should be produced. The responding party generally has 30 days to serve a written response — 45 days for a defendant served along with the summons and complaint — stating for each item or category whether inspection will be permitted as requested or objecting with specific grounds, including any objection to the requested form for producing electronically stored information, and stating whether responsive material is being withheld on the basis of an objection. Unless the parties agree or the court orders otherwise, a party producing documents must produce them as they are kept in the ordinary course of business or organize and label them to match the categories in the request, and electronically stored information that was not requested in a particular form must be produced in the form it is ordinarily maintained in or in a reasonably usable form, with no obligation to produce the same information in more than one form.
Rule 34.03 makes clear that a person who is not a party can still be compelled to produce documents and tangible things, or to permit an inspection, through the subpoena procedure in Rule 45, rather than through a separate action. Requests under Rule 34 are frequently challenged for lacking the "reasonable particularity" the rule demands — a request broad enough to sweep in everything "relating to" a subject, or one that does not identify specific devices or files with enough precision, risks being found insufficient even when the underlying material sought is plainly relevant.
Frequently Asked Questions
Can I get documents from someone who is not a party to the lawsuit?
Not directly through Rule 34. Rule 34.03 requires a nonparty's documents or tangible things to be obtained through a Rule 45 subpoena rather than through a Rule 34 request, which applies only between parties.
In what format do electronic documents have to be produced?
Rule 34.02 lets the requesting party specify a form for electronically stored information. If no form is specified, the responding party must produce it in the form it is ordinarily maintained in or in a reasonably usable form, and need not produce the same information in more than one form.
How specific does a document request have to be?
Rule 34.02 requires each item or category to be described with reasonable particularity. Requests that are too broad or vague — such as asking for everything "relating to" a subject without more — risk being found insufficient even when the material sought is relevant.
Source & verification. The rule text and Advisory Commission Comments are reproduced verbatim from the
official Tennessee Rules of Civil Procedure (Tenn. R. Civ. P. 34). Prescribed by the Supreme Court of Tennessee (Tenn. Code Ann. §§ 16-3-402 to 16-3-407, 16-3-601). The plain-English summary is original and written by us. Last verified July 2, 2026. ·
Official source
Also known as: request for productionentry upon land for inspectionreasonable particularityelectronically stored information
Advisory Commission Comments.
This Rule provides a method by which a party may obtain access to relevant material objects under the control of another party. This procedure has long been established in the Federal Rules of Civil Procedure. It has not had an exact equivalent in Tennessee procedure, although a somewhat similar procedure was authorized under Tenn. Code Ann. § 24-1101 et seq. [repealed].
34.01: The provisions of this rule [in 1984] permit a party to obtain documents which are subject to another party's effective control (e.g., medical records). [1984.]
34.02: A party responding to a request for production obviously must produce documents. To alleviate occasional abuses whereby a party will change the usual organization of files, the [1984] amendment requires either arrangement of records as kept in the course of business or rearrangement to track the request. [1984.]