Have you ever had a situation where the opposing side has responded to each of your document production requests with the response?
All responsive documents within the custody and control of responding party will be produced.
and then they dump thousands of documents on you with no rhyme or reason as to how they are organized.
You then diligently send your meet and confer letter stating that the documents are so disorganized that you “can’t make heads or tails as to which documents are responsive to which request.” Opposing counsel responds saying that the document production was in compliance with the code as the documents were produced “as they are kept in the usual course of business” and they will neither modify their response nor the production. So what do you do?