A complete recital of all such interactions is well beyond the scope of this motion. The following examples are more than sufficient for Rule 34(a) purposes. • HSBC consolidates Household’s financial performance on its financial statements.

While the rule does not specify the time period a party must give the subpoenaed entity or person to comply with the subpoena, the period must be reasonable. Here, Plaintiff’s request does not comply with the FRCP 34 as the demand for documents does not provide the requisite 30 day response period. This is not a sufficient period of time for Vanguard to review, gather and comply with the Notice, especially in light of the significant Case 2:17-cv-01788-JAD-PAL Document 122 Filed 03/24/18 Page 7 of 12 34200961v1 Page 8 of 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 amount of paper work that is demanded by each Notice. On this basis alone, the Court should quash the Notice.

Pursuant to Federal Rule of Civil Procedure 34(b)(2), Responding Party will produce a copy of said document concurrently with this Response. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 24 26 27 28 REQUEST NO. 10: All documents which reflect any post-conviction relief you have obtained in the underlying action. RESPONSE TO REQUEST NO. 10: Pursuant to Federal Rule of Civil Procedure 34(b)(2), Responding Party does not possess any documents responsive to this Request

My business address is 3960 Howard Hughes Parkway, Suite 300, Las Vegas, Nevada 89169. On November 9, 2015, I served the within document: DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL TO ALLOW RULE 34 INSPECTION Of ORIGINAL CCSD DOCUMENTS 6 By CM/ECF Filing — Pursuant to FRCP 5(b)(3) and LR 5-4, the above-referenced document was electronically filed and served upon the parties listed below through the Court’s Case Management and Electronic Case filing (CM/ECF) system: Kathleen J. England, Esq.

Case 8:15-cv-01708-SDM-TGW Document 398 Filed 07/20/18 Page 13 of 15 PageID 2911 14 39. And in the spirit of resolution, given that Rule 34(a)(1), Fed.R.Civ.P. provides for physical inspection of original records in lieu of production of copies, Defendant re-

67. And in the spirit of resolution, given that Rule 34(a)(1), Fed.R.Civ.P. provides for physical inspection of original records in lieu of production of copies, Defendant re-offers Relator’s counsel direct access to Defendant’s corporate records and telephone.

19 RESPONSE TO REQUEST NO.8: 20 21 22 23 Craig Denney E-Mail to Paris Rich, Courtroom Administrator to Judge Howard D. McKibben, United States District Court, District of Nevada, on August 24, 2015 re: United States v Serenbetz. Pursuant to Federal Rule of Civil Procedure 34(b)(2), Responding Party 24 will produce a copy of said document concurrently with this Response. 25 26 27 28 REQUEST NO. 9: All documents which reflect damages you claim as a result of Cross-Defendants' alleged disclosure of your private

The Ex Parte should be denied. // // Case 2:11-cv-10556-PA-SS Document 99 Filed 09/06/12 Page 6 of 7 Page ID #:1392 -6- DEFENDANT’S OPPOSITION TO PLAINTIFFS’ EX PARTE APPLICATION FOR AN ORDER COMPELLING DEFENDANT TO COMPLY WITH F.R.C.P. 34(B)(2)(E)(I) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IV. CONCLUSION For all of the foregoing reasons, Defendant respectfully requests that the Court deny Plaintiffs’ Ex Parte Application.

(Sacramento Decl., ¶ 6 (reflecting $8,500.00 for Ms. Sacramento's work on this motion), Patch Decl., ¶ 21 (reflecting 3 Apparently, it is not rare for opposing counsel to deliberately produce documents out of order. [Fed.R.Civ.P. 34 Advisory Committee Notes (1980).] 4 B.K.B v. Maui Police Dept., 276 F.3d 1091, 1106 (9th Cir. 2002) (sanctions pursuant to section 1927 are supported by a finding of recklessness, and sanctions pursuant to a court's inherent power are supported by bad faith); New Alaska Dev. Corp. v. Guetschow, 869 F.2d 1298, 1306 (9th Cir. 1989) (tactics undertaken with the intent to increase expenses or delay may support a finding of bad faith).

The completeness of the documents produced pursuant to Fed. R. Civ. P. 34. The authenticity of the documents produced pursuant to Fed. R. Civ. P. 34. I 11 if II it Case 4:15-cv-00565-JED-TLW Document 36-13 Filed in USDC ND/OK on 10/18/16 Page 7 of 7