Document requests may include documents 'sufficient to show' where compilations would provide the desired information.

Document requests may include documents 'sufficient to show' where compilations would provide the desired information.

• A. Requests should only seek documents that are already produced.
• B. Requests may ask for documents 'sufficient to show' where compilations would provide the desired information.
• C. Requests should not use 'sufficient to show' phrasing.
• D. Requests must specify every document with exact content.

Answer: (B)

In discovery, you can frame requests to obtain the needed information even if it’s not found in a single document by asking for documents that are “sufficient to show” the information, especially when pulling together compilations would reveal what’s needed. This approach respects practicality and proportionality: the goal is to obtain the facts, not to produce every individual page of every file. If a set of documents or a compiled summary can demonstrate the desired information, that suffices, and the responding party can assemble that material rather than insisting on exact, line-by-line content of every document. That’s why choosing the option that allows requests for documents “sufficient to show” where compilations would provide the desired information is best. The other options push an overly narrow or burdensome approach: requiring only already produced documents ignores the value of assembling a helpful compilation; prohibiting the phrase undermines a practical method for obtaining information; and demanding exact content of every document is usually impractical and unnecessary for the purposes of discovery.

In discovery, you can frame requests to obtain the needed information even if it’s not found in a single document by asking for documents that are “sufficient to show” the information, especially when pulling together compilations would reveal what’s needed. This approach respects practicality and proportionality: the goal is to obtain the facts, not to produce every individual page of every file. If a set of documents or a compiled summary can demonstrate the desired information, that suffices, and the responding party can assemble that material rather than insisting on exact, line-by-line content of every document.

That’s why choosing the option that allows requests for documents “sufficient to show” where compilations would provide the desired information is best. The other options push an overly narrow or burdensome approach: requiring only already produced documents ignores the value of assembling a helpful compilation; prohibiting the phrase undermines a practical method for obtaining information; and demanding exact content of every document is usually impractical and unnecessary for the purposes of discovery.