Where a claim of privilege is asserted in responding or objecting to any discovery requested in requests
for documents, and information is not provided on the basis of such assertion, the party asserting the privilege
shall in the response or objection identify the nature of the privilege (including work product) which is being
claimed and if the privilege is being asserted in connection with a claim or defense governed by state law, set
forth the state privilege rule being invoked. When any privilege is claimed, the party asserting it shall indicate,
as to the information requested, whether any such documents exist.
