(a) Form of Response.
Each answer, statement, or objection shall be preceded by the request to which it
responds.
(b) Objections to Document Requests.
(1) When an objection is made to any document request or sub-part, it shall
state with specificity all grounds for the objection. Any ground not stated in
an objection within the time provided by the FR Civ P 34, or within any
extensions of time, is waived.
(2) No part of a document request shall be left unanswered because an objection
was interposed to another part of the document request.
(c) Answers to Document Requests Following Objections.
When it is ordered that document requests to which objections were made must be
answered, the answers shall be served within 14 days of the order, unless the court
directs or the parties stipulate otherwise.
