According to Rule 34 of the FRCP, a party in litigation may serve on any other party a request for production of relevant documents. This request must specify with reasonable particularity each item or category of new items to be inspected. The request must also specify the form in which ESI is to be produced. Here in this blog, we provide a sample request which defines the form of production. Aside from this, you will also need to keep in mind other requirements in rule 34 and rule 26 in which you must discuss other issues relating to, specificity, the eDiscovery process, timing and production delivery/accessibility.