The Court held that a notice to produce under UCPR r 21.10(1)(b) must identify an individual document by characteristics peculiar to itself (e.g., a letter of a given date from X to Y), and descriptions calling for classes of documents are impermissible. By contrast, a notice under r 34.1 operates akin to a subpoena and permits broader descriptions provided documents are specified with reasonable particularity, but must not use terms so wide as to encompass a multitude of documents (such as 'concerning'), nor require the recipient to form legal conclusions about a document's effect. The notice under r 21.10 was set aside, and a limited r 34.1 notice (paragraph 2 only) was permitted to proceed.
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