Walk into meet-and-confer with proportionality
Prepare discovery negotiation choices around relevance, burden, value, and alternatives.
01 Diagnose 02 Offer 03 Fresh ask Scope pressure The request is broad enough to make review cost the case strategy. A pure no sounds obstructive; a pure yes lets volume replace judgment. Proportionality lens Burden plus alternative beats burden alone A proportionality argument should connect requested information, likely value, cost or burden, and a narrower route that still tests the relevant issue. Reflex Object broadly and hope pressure works The team can negotiate scope without looking evasive. Proportionality is strongest when you bring a workable alternative, not just a complaint about cost. Diagnose the request Before the call
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