e-Discovery Team

Ralph Losey. Published April 28, 2023.

Rule 34 FRCP, Written as New Poetry, with Chat GPT.

All Inspiration, Prompts and Sane QC by Me, Human Ralph Losey.

I end this poetry series with a different twist. The translation of Rule 34 is again by ChatGPT4, but this time the animation reading is by me, Ralph Losey. Well, my voice anyway. Also, I put the reading up front, rather than at the end. The video is not of me, or an avatar I created, but instead uses a well-known drawing of Shakespeare. The drawing is animated and lip-synced to my reading by a new program I’m trying out, HeyGen.

It is still amazing to me how ChatGPT4’s poetic renderings open up new insights and perspective in these very complex and otherwise dry and somewhat boring Federal Rules of Civil Procedure. Any law professors or other instructors are welcome to use these poems with their students.

If you have not noticed, the two intro paras above to this series have been Haikus. Here is one more Haiku with advice to all dear readers before they listen to the reading.

Listen to the heart

Of the rule’s deep poetry;

Sit back and relax.

In the realm of federal procedure, where justice oft’ weaves,

Rule 34, a tale of documents and electronically stored leaves,

A party’s quest to gather knowledge from the depths of cyberspace,

To bring forth truth and understanding in a legal embrace.

With scope laid out by Rule 26(b), the path to knowledge clear,

Request to produce, permit inspection, test, or sample, my dear,

From designated documents and data, to tangible things,

To entering lands and properties, where secrets may take wings.

Through writings, drawings, graphs, and charts, the stored information flows,

In photographs and sound recordings, a digital garden grows,

Translated by the diligent hand, to a form that all may see,

This rule, the guide, the cornerstone, of discovery’s decree.

The request must bear the hallmarks of a reasonable pursuit,

Particularity, time and place, in the inspection’s route,

A form or forms may be specified for electronic yield,

So harmony in production and requests may be revealed.

A time to respond, the clock begins, with thirty days to spare,

From service or, with Rule 26(d)(2), from the conference fair,

A shorter or a longer time, by stipulation or court’s decree,

The response, a dance of words, objections and discovery.

Each item met with an embrace, or an objection swift and true,

Grounds for such, with reasons laid, the path of knowledge to construe,

Copies offered in lieu of inspection, a gesture of goodwill,

But within the time specified or reasonable, the quest fulfill.

Objections, oh, objections! The shield against unwarranted pry,

Responsive materials withheld, the basis must not belie,

Partial objection, clear and specific, permit inspection of the rest,

In the dance of words and reason, the truth shall be undressed.

The form, the form, the electronic form, in which the data’s shown,

Objecting to the requested, or when no form was known,

The party states the form they choose, the data to bequeath,

For producing the documents or electronically stored wreath.

As kept in course of business, or with categories matched,

The documents produced, the knowledge sought, the stories to be hatched,

Ordinarily maintained, or reasonably usable forms ensue,

Not once, but twice, the same information need not accrue.

Nonparties, too, may feel the touch of Rule 45’s embrace,

Compelled to produce or permit, the truth they must not chase,

The inspection, documents, and tangible things, their role to play,

In the quest for justice, truth, and light, that ever leads the way.

Upon the stage of litigation, where actors gather ’round,

The dance of words and reason, in harmony, profound,

The rhythm of the rules, the beat of the procedure’s heart,

The melody of justice, where every note plays a part.

The clock ticks on, the days pass by, the deadline drawing near,

The response to come, with words of wisdom, objections to appear,

And as the dance continues, a ballet of legal grace,

Each step a move toward understanding, the truth to embrace.

Through the twists and turns of reason, the maze of legal thought,

A path emerges, clear and bright, the sought-for knowledge caught,

The documents, the data, the tangible and more,

Revealed, unfurled, presented, by the guiding hand of Rule 34.

And as the dance concludes, the final notes of justice played,

The truth unveiled, the knowledge gained, the foundation firmly laid,

A story told, a tale complete, through the labyrinth of the law,

By the guiding hand of Rule 34, where discovery was the draw.

Oh, Rule 34, your words of wisdom, your tapestry of fate,

A pillar of the justice system, your power to illuminate,

In the realm of federal procedure, where justice oft’ weaves,

A beacon of light, a guide, through the depths of cyberspace’s leaves.

Ralph Losey Copyright 2023 — All Rights Reserved