(a) Unless the parties agree otherwise, within 60 days from the date a discovery request is received, the party receiving the request must either:
(1) Produce the requested documents or information to all other parties by serving the requested documents or information by first-class mail, overnight mail service, overnight delivery service, hand delivery, email or facsimile;
(2) Identify and explain the reason that specific requested documents or information cannot be produced within the required time, state when the documents will be produced, and serve this response on all parties and file this response with the Director; or
(3) Object as provided in
Rule 13508and serve this response on all parties and file this response with the Director.
(b) A party must act in good faith when complying with paragraph (a) of this rule. "Good faith" means that a party must use its best efforts to produce all documents required or agreed to be produced. If a document cannot be produced in the required time, a party must establish a reasonable timeframe to produce the document.
(c) If a party redacts any portion of a document prior to production, the redacted pages (or range of pages) shall be labeled "redacted."