41. Rangely sues Plante Laboratories for injuries allegedly caused by its asthma drug, Pro- Nosatrol. Suit is brought in federal court in Arizon where Plante has its principal place of business. Rangeley's lawyer sends Plante a Rule 34 Request for "all documents, files, and other records relating to the pre-market testing of the drug Pro-Nosatrol, whether in hard copy or electronic form, including e-mail and voice mail, deleted files, hard drives, laptops, and other electronic devices or storage systems. Most documents concerning the testing are in the possession of Advanced Testing Company, an independent testing laboratory in Florida that contracts with Plante to test its new pharmaceutical products. Plante's counsel should object to the request because a. the records at Advanced Testing are in the possession of an independent company, not the defendant b. the records at Advanced Testing are not present in Arizona, and therefore are not subject to the jurisdiction of the court c. the request is too broad, since it seeks records in electronic form as well as hard copy, which would have to be retrieved by computer professionals d. the request does not describe the records sought with reasonable particularity e. none of the listed objections is likely to be accepted by the court