Knowledge Fight

#685: Formulaic Objections Part 7

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May 25, 2022
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INSIGHT

One Rep Can't Cover Everything

  • A single corporate representative cannot reasonably prepare to cover tens of thousands of pages in two weeks.
  • Assign multiple designees for complex discovery to avoid intentional or accidental noncompliance.
INSIGHT

Preserve Before You Search

  • Corporate reps must preserve evidence proactively, not just search for production items.
  • Saying "I don't know" about preservation invites sanctions and judicial suspicion.
ANECDOTE

Emails Show Prior Research On Plaintiffs

  • Free Speech Systems had internal emails showing pre-lawsuit research on plaintiffs, yet the corporate rep claimed ignorance.
  • That missed awareness revealed failure to review produced documents and harmed their credibility.
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