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.

Hon. Jay Young (Ret.) is a retired judicial officer with decades of experience presiding over complex civil litigation matters. Following a distinguished career on the bench, Judge Young now serves as a mediator, arbitrator, and court‑appointed special master, and discovery referee. Judge Young brings a disciplined, impartial, and results‑oriented approach to dispute resolution. Judge Young is based in Nevada and accepts appointments statewide and nationally, subject to agreement or court order. He can be reached at 855.777.4557 or info@armadr.com
Known for judicial temperament, analytical rigor, and practical problem‑solving, Judge Young assists litigants and counsel in resolving high‑stakes disputes efficiently and with integrity and employing best practices. He is recognized by U.S. News and World Report’s publication Best Lawyers as Arbitration Lawyer of the Year.