(a) Discovery requests served pursuant to Fed. R. Civ. P. 33, 34, and 36
shall be in a form providing sufficient space to respond following each request.
(b) Responses to discovery requests pursuant to Fed. R. Civ. P. 33, 34,
and 36 shall set forth the interrogatory or request in full before the response. Each
objection shall be followed by a statement of the reasons therefor. Boilerplate and
generalized objections are not permitted.
(c) A motion to compel discovery shall set forth only the pertinent
interrogatories, requests for production, or requests for admissions, and answers or
objections.
(d) When a claim of privilege is made in response to any discovery
request pursuant to Fed. R. Civ. P. 33, 34, or 36, unless otherwise agreed to by the
parties, the materials or information claimed to be privileged shall be identified
with reasons stated for the particular privilege claimed. No generalized claim of
privilege shall be allowed. An assertion of privilege or work product should, on a
schedule agreed to by the parties or ordered by the court, contain the following for
each document, communication, or piece of information withheld:
(1) Date of the creation of the document;
(2) Author;
(3) Primary addressee(s) and the relationship of that person(s) to
the client and/or author of the document;
(4) Secondary addressee(s) and the relationship of that person(s) to
the client and/or author of the document;
(5) Type of document;
(6) Client (party asserting the privilege);
(7) Subject matter of the document or privileged communication;
(8) Basis for the legal claim of privilege, work product, or other
objection to production; and
(9) Document identifier (e.g., Bates number).
