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    May I ask what documents reviewed by the 30(b)(6) designated person reviewed to prepare for the deposition ...

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    I wouldn't worry too much about the jury instruction. Your client does have the ultimate burden, but ...

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    You are correct that discovery imposes a duty to search for responsive information. See generally General ...

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    Defendant responds to me-too interrogatories only by identifying plaintiffs in other cases handled by ...

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