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One of the most important aims of the 2015 amendments to the Federal Rules of Civil Procedure was the elimination of “unnecessary or wasteful discovery.” While a worthy objective, this goal is often elusive. Counsel, clients, and even the courts often get caught up in ensuring that every responsive document has been produced or otherwise accounted for in discovery. Though understandable, this approach is an unproductive and exhausting discovery trap. It squanders resources while failing to accomplish the very purposes for which discovery has been undertaken.

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