Requests for “Any and All” Documents Are Obsolete – Update
E-Discovery LLC
JULY 6, 2024
In a 2021 blog, I wrote that Requests for “Any and All” Documents Are Obsolete. That blog suggests alternative approaches. Recently, in Nelson v. I.Q. Data International, Inc., 2024 WL 2963790 (E.D. Mich. June 12, 2024), the court wrote: Courts have long condemned omnibus “any and all” document requests. See Cheney v. U.S. Dist. Court for D.C. , 542 U.S. 367, 387-88 (2004) (document requests asking “for everything under the sky” were “anything but appropriate”); Effyis, Inc. v.
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