It is not enough to present the court with a litany of numbers to quantify the volume of information sought. To make an effective proportionality argument against a burdensome request, one should also provide quantitative and qualitative context for those numbers.
Proportionality
Practical considerations for litigating proportionality
It is not enough to present the court with a litany of numbers to quantify the volume of information sought.
Key Takeaway
Proportionality not only weighs the burden, but also the relative need—or lack thereof—for the information itself.


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McGinn, Sakiyama, and Bartholomay, Practical Considerations for litigating proportionality, Law 360 (May 4, 2018)