If you cannot afford to sift through tens (or hundreds) of thousands of your opponent's documents "fishing" for something useful, simply don't. With respect to the discovery you need, be mindful that there are typically about 30 documents that will actually matter at trial or on summary judgment . Many of these documents will be known to the attorneys and/or clients in advance. So target the information you know you will need.
SEARCH FOR EVIDENCE YOU WILL ACTUALLY NEED
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