Sort Objections That Actually Work
Classify discovery response language by whether it states a specific basis and production impact.
Sort each discovery response phrase by its quality. Specific and usable Boilerplate risk Needs production impact Better as a meet-and-confer point Objection to products outside Atlas and dates before Jan 1, 2024; withholding materials outside that product/date scope. Subject to the objection, will produce nonprivileged Atlas approval emails from agreed custodians for Jan-Sep 2024. Objection, vague, overbroad, unduly burdensome, and not proportional. Subject to and without waiving the foregoing objections, responding party will produce responsive documents. Request is unduly burdensome because it requires backup restoration. Request is overbroad to the extent it seeks non-Atlas products. Propose CRM export first, then…
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