Under the most recent version of the Federal Rules of Civil Procedure, a party objecting to a request for production of documents may not rely on the hackneyed objection that the request is “not reasonably calculated to lead to the discovery of admissible evidence.” Under the new standard, the threshold question is whether a request is “relevant to any party’s claim or defense.” Fed. R. Civ. P. 26(b)(1).
Second, when responding to request for production of documents under Fed. R. Civ. P. 34, an objecting party must state both the specific grounds for the objection but also must state whether any responsive materials are being withheld on the basis of the objection.