What standard is required for identifying documents in a notice to produce?

Identification with reasonable precision is the appropriate standard for identifying documents in a notice to produce. This means that the documents requested must be described clearly enough to enable the person or party that receives the notice to understand what is being requested and to locate those documents without undue difficulty. Reasonable precision balances the need for specificity with practicality, avoiding overly broad or vague descriptions that could lead to confusion or disputes over what documents are to be produced.

This standard ensures that the requesting party has access to relevant evidence while protecting the producing party from excessive or irrelevant demands. It is an essential aspect of the civil procedure aimed at promoting efficiency in the pre-trial process and ensuring that both parties can adequately prepare for trial. The other options lack this necessary balance; general descriptions could lead to misunderstandings, highly detailed specifications may be overly burdensome and impractical, and broad descriptions may not provide the clarity needed for compliance.