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LITIGATION-MANAGEMENT4 MIN READ

Meet-and-confer battlecard

Recall principled responses to common discovery scope pressure points.

Opposing counsel pushes for broad discovery and frames your scope limit as obstruction. If your client has nothing to hide, produce the full channel history. We understand you need communications about approval timing. The proportional path is to start with the two approval custodians, the renewal period, and the project channel, then expand if hit reports show relevant discussion outside that set. The response separates the legitimate information need from the overbroad position, offers a concrete alternative, and names a trigger for expansion. It is cooperative without conceding unlimited scope. Hidden-data accusation You need to avoid a defensive tone while…

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