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What is the discovery fight? What’s his basis for not giving you access? Are you unable to just access the documents in the system?
Why would you not have access? What is the purpose of that?
I wouldn’t do it…
I would just say that I’m not doing it because I don’t have the relevant context and would be likely to weaken our position.
This post needs more context. You really shouldn’t need to spend time (and money) pouring over discovery documents here. If they didn’t produce x and this was confirmed, you have to trust your team that they’re not there. The person who is not giving you access to them may be doing so for a legitimate purpose—ensuring that you don’t waste time doing just that. Write what is needed, make caveat after caveat to whom you’re delivering this motion (or whatever it is) and don’t sign it.