The request for production of documents under Federal Rule of Civil Procedure 34 is the discovery device that actually moves the evidence, and how a party objects and responds to it frequently decides whether a case settles, wins, or ends in sanctions. This guide works through the scope of discovery under Rule 26(b)(1) and the 2015 proportionality amendments, the structural commands of Rule 34(b)(2)—including the duty to state whether documents are being withheld—and the judicial hostility to boilerplate objections that has grown up around Fischer v. Forrest and Rule 26(g). It treats electronically stored information at length: form of production, native versus imaged files, metadata, collaboration-tool data, inaccessible sources and cost-shifting, and technology-assisted review. It also covers the attorney-client privilege and work-product doctrine, privilege logs, waiver and the Rule 502(d) order, preservation and spoliation under Rule 37(e), motions to compel, the meet-and-confer duty, protective orders, and third-party subpoenas under Rule 45. Worked hypotheticals and model response language run throughout, written so that a judge, a practitioner, and a business owner can each follow the mechanics and the strategy.