LITIGATION-MANAGEMENT5 MIN READ
Negotiate discovery scope without posturing
Use principled negotiation moves to turn a discovery fight into a narrower, evidence-focused exchange.
Dana OC Opposing counsel I Interest O Options C Criteria Meet-and-confer 3 min The moment The accusation is sharp, but the real work is designing a discovery path that tests the issue without overcollection. Position fighting creates motion practice. Interest framing creates options. 38 requested custodians 5 yrs requested date range
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