E-DISCOVERY5 MIN READ
Negotiate Search Terms Without Theater
Use cooperative, evidence-based language to negotiate search scope.
Opposing counsel OC Requesting party R Reframe T Test P Protocol Meet and confer 20 sec The moment The other side wants 86 terms. Your initial hit count is 410,000 before family expansion. A flat refusal sounds evasive; blind agreement creates review waste. 86 proposed terms 410k raw hits
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