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It turns out that Jean-Paul Sartre’s famous pronouncement that “hell is other people” was overly broad. Other people per se are not the problem, but rather other lawyers—and uncooperative ones at that. A federal judge in the late 1980s confirmed as much, as a recent e-discovery opinion reminds us: “If there is a hell to which disputatious, uncivil, vituperative lawyers go, let it be one in which the damned are eternally locked in discovery disputes with other lawyers of equally repugnant attributes.”1

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