There’s a special place in hell for people who draft anything over 20 requests for production.

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Please provide all documents relevant or related to the last 25 years of your mortal existence, including but not limited to all family members known or unknown and any potential future family members.

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Actually, provide all the irrelevant stuff too 🎣

likefunny

I do first property as well and have had about 45 RFP. Absolutely ridiculous

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There’s just no need!!

And before people get crazy, it’s a basic first party property case. Nothing complex here.

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I’m on a 77 rfp one and each one says “all documents that relate to the allegations in paragraph X of the complaint” and this case had 4 independent investigations with millions of documents, interviews, texts and emails. Insane.

Requests for production are easy though. It's the requests for admission that are the problem.

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CA Form Rogs have a question like, for every RFA where your response is not an unqualified admission, set forth all facts / ID all witnesses & documents X_X

We got 160 RFPs for a simple FELA case. How ridiculous is that?

Yeah I tried to strike anything above 35 as harassing and duplicative and judge got mad lol

Amen to that. Try 200 plus requests. 😑

Yeah. About that. I treat discovery like I am the 8th army air corps. We just served 800 plus rfps. I promise you - he deserves it

I had a special master say 700+ doc requests and rogs was not burdensome, and gave us 30 days to respond. Insane amount of work. Crazy decision.

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likehelpful

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