N.Y. Comp. Codes R. & Regs. Tit. 22 r. 202.70.11-e - Responses and Objections to Document Requests

(a) For each document request propounded, the responding party shall, in its Response and Objections served pursuant to CPLR 3122(a) (the ''Responses''), either:

i. state that the production will be made as requested; or

ii. state with reasonable particularity the grounds for any objection to production.

(b) By a date agreed to by the parties or at such time set by the Court, the responding party shall serve the Responses contemplated by Rule 11-e(a)(ii), which shall set forth specifically:

(i) whether the objection(s) interposed pertains to all or part of the request being challenged;

(ii) whether any documents or categories of documents are being withheld, and if so, which of the stated objections forms the basis for the responding party's decision to withhold otherwise responsive documents or categories of documents; and

(iii) the manner in which the responding party intends to limit the scope of its production.

(c) By agreement of the parties to a date no later than the date set for the commencement of depositions, or at such time set by the Court, a date certain shall be fixed for the completion of document production by the responding party.

(d) By agreement of the parties to a date no later than one (1) month prior to the close of fact discovery, or at such time set by the Court, the responding party shall state, for each individual request:

(i) whether the production of documents in its possession, custody or control and that are responsive to the individual request, as pro- pounded or modified, is complete; or

(ii) that there are no documents in its possession, custody or control that are responsive to the individual request as propounded or modified.

(e) Nothing contained herein is intended to conflict with a party's obligation to supplement its disclosure obligations pursuant to CPLR 3101(h).

Notes

N.Y. Comp. Codes R. & Regs. Tit. 22 r. 202.70.11-e

Adopted New York State Register April 29, 2015/Volume XXXVII, Issue 17, eff. 4/1/2015 Amended New York State Register August 22, 2018/Volume XL, Issue 34, eff. 10/1/2018 Amended New York State Register April 13, 2022/Volume XLIV, Issue 15, eff. 4/11/2022