Writing
Plaintiff-side litigation strategy — evidence, economics, procedure, and the asymmetries between the two sides.
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Seven Things to Measure When Two Million Documents Arrive
The shape of a production is evidence about the party that produced it, and all of it can be counted before a document is opened.
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The Document Dump Is an Economic Weapon
Withholding documents is dangerous. Producing too many is not. Volume does not destroy evidence — it relocates cost.
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Build the Verdict Form Before You Review Discovery
The verdict form is the only document that states, in the court's own words, what you have to prove. It is usually the last thing anyone writes.
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Stop Reviewing Documents. Start Constructing Evidence.
Review asks whether a document is responsive. Construction asks whether it proves an element. Only one of those is your frame.