SUPERIOR CIVIL RULE 34                                       
         PRODUCTION OF DOCUMENTS AND THINGS AND ENTRY UPON                       
             LAND FOR INSPECTION AND OTHER PURPOSES                              
                                                                                 
    (a) Scope. Any party may serve on any other party a                          
request (1) to produce and permit the party making the                           
request, or someone acting on his behalf, to inspect and                         
copy, any designated documents (including writings,                              
drawings, graphs, charts, photographs, phonorecords, and                         
other data compilations from which information can be                            
obtained, translated, if necessary, by the respondent                            
through detection devices into reasonably usable form), or                       
to inspect and copy, test, or sample any tangible things                         
which constitute or contain matters within the scope of rule                     
26(b) and which are in the possession, custody or control of                     
the party upon whom the request is served; or (2) to permit                      
entry upon designated land or other property in the                              
possession or control of the party upon whom the request is                      
served for the purpose of inspection and measuring,                              
surveying, photographing, testing, or sampling the property                      
or any designated object or operation thereon, within the                        
scope of rule 26(b).                                                             
    (b) Procedure.  The request may, without leave of court,                     
be served upon the plaintiff after the summons and a copy of                     
the complaint are served upon the defendant, or the                              
complaint is filed, whichever shall first occur, and upon                        
any other party with or after service of the summons and                         
complaint upon that party.  The request shall set forth the                      
items to be inspected either by individual item or by                            
category, and describe each item and category with                               
reasonable particularity. The request shall specify a                            
reasonable time, place and manner of making the inspection                       
and performing the related acts.                                                 
    The party upon whom the request is served shall serve a                      
written response within 30 days after the service of the                         
request, except that a defendant may serve a response within                     
40 days after service of the summons and complaint upon that                     
defendant. The parties may stipulate or the court may allow                      
a shorter or longer time. The response shall state, with                         
respect to each item or category, that inspection and                            
related activities will be permitted as requested, unless                        
the request is objected to, in which event the reasons for                       
objection shall be stated. If objection is made to part of                       
an item or category, the part shall be specified and                             
inspection permitted of the remaining parts.  The party                          
submitting the request may move for an order under rule                          
37(a) with respect to any objection to or other failure to                       
respond to the request or any part thereof, or any failure                       
to permit inspection as requested.                                               
    A party who produces documents for inspection shall                          
produce them as they are kept in the usual course of                             
business or shall organize and label them to correspond with                     
the categories in the request.                                                   
    (c) Persons Not Parties. This rule does not preclude an                      
independent action against a person not a party for                              
production of documents and things and permission to enter                       
upon land.