Indeed, as Chief Justice John Roberts aptly put it, “he amendments may not look like a big deal at first glance, but they are.” See 2015 Year-End Report on the Federal Judiciary.įirst, parties should no longer use broad document requests such as produce “any and all” or “each and every” document. The December 2015 changes to Rule 34(b) are dramatic in the way document requests and objections will be handled in federal practice.