W.D. Pa. LCvR 34

A. Electronic Form. Any party may, pursuant to Rule 34 of the Fed. R. Civ. P.,

serve upon any other party requests for production in Writable Electronic Form

(as defined in LCvR 33.B) and require that written responses thereto also be

provided in electronic form, except that a party producing documents or

electronically stored information shall produce them in the manner and form as

may be permitted or required pursuant to Fed. R. Civ. P. 34(b)(2)(E). Upon

request by any party, requests for production must be served upon the

requesting party in Writable Electronic Form. Unless the serving party

specifically requests that the written responses be provided in hard-copy form,

the responding party shall provide the written responses to such requests for

production in electronic form. Any party responding in electronic form to requests

for production may serve such written response in a form which may not be

altered.

B. Hard Copy Form. In the event that the parties elect not to use the electronic

form for requests for production or written responses thereto, requests for

production shall be prepared in such a fashion that sufficient space for insertion

of the written responses thereto is provided after each request or sub-section

thereof. The original and two (2) copies shall be served upon the party to whom

such request for production is directed. The responding party shall insert written

responses on the original request for production served upon him or her and

shall retain the original and be the custodian of it. If there is not sufficient space

on the original for insertion of written responses, the responding party may use

and attach supplemental pages for the written responses. In lieu of the foregoing

procedure, the responding party may retype each request with the written

response to each such request appearing immediately thereafter.