With no explanation, chose the best option from "A", "B", "C" or "D". was being requested”); Employers Ins. Co. of Wausau v. Nationwide Mut. Fire Ins. Co., Civ. No. 2005-0620, 2006 WL 1120632, *2 (E.D.N.Y. Apr. 26, 2006). (“This Court finds that the defendant’s letter sufficiently described the documents sought [for Rule 34 purposes].”). This Court’s research reveals that other federal district courts have ruled that informal requests are insufficient, at least in situations wherein the requesting party later sought to compel the informal Rule 34 request. See, e.g., Sithon Mar. Co. v. Holiday Mansion, Civ. No. 96-2262-EEO, 1998 WL 182785, *2 (D.Kan. Apr. 10, 1998) (finding that plaintiffs letter requesting documents, which was filed after the fact discovery period closed, did not satisfy Rule 34); Suid v. Cigna Corp., 203 F.R.D. 227, 228 (D.Vi.2001) (<HOLDING>). The Court notes that the inconsistent case

A: recognizing rule
B: holding that notice to counsel may be waived
C: recognizing this rule
D: holding that correspondence between counsel cannot suffice as a rule 34 request that may be compelled through rule 37
D.