“When you’re making an argument in the discovery context, know your data”
This is such a great quote. I find it amazing how many times I hear of people showing up for meet and confers or sending responses to production requests who haven’t taken the time to understand the data that might be involved.
It can lead to some really embarrassing missteps, like agreeing to search therms that are obviously not good, or misunderstanding how burdensome a production might actually be. That’s not great.