Draft a proportional Rule 34 request
Draft a document request that identifies subject, source, time period, and production form.
Convert 'all documents relating to Project Atlas' into a request that is particular and proportional. Issue + source + time + form Broad relationship words like 'relating to' can be necessary, but standing alone they create burden fights and vague collection. Tie to issue Name the disputed defect: payment-failure defects in Project Atlas. The request should connect to claims or defenses, not a whole business project. Name sources Identify Jira, Slack, and project email repositories. Source naming helps with reasonable search planning and meet-and-confer. Limit time Use March 1 to September 30, 2024, matching rollout through remediation. A date range…
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