Generate a privilege-log-compliant Discovery Request List for plaintiff-side employment discrimination litigation in federal district court, including itemized requests for electronically stored Slack messages and mobile device metadata from 2020–2023

Generate generate a privilege-log-compliant discovery request list for plaintiff-side employment discrimination litigation in federal district court, including itemized requests for electronically stored slack messages and mobile device metadata from 2020–2023 for Legal Services industry

Legal Services

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Allowed: PDF, DOCX, TXT, XLSX, MSG

Max size: 50MB

Upload key case documents (Complaint, Schedule A exhibits, prior discovery responses, privilege log templates)
Underlying legal theory of discrimination alleged in the complaint
Size and nature of the defendant employer for proportionality analysis
Enter names, titles, and relationships of key decision makers central to the discriminatory acts (max 8 individuals)
Specify exact date range for electronically stored information (ESI) requests including mobile devices and Slack
Federal district court jurisdiction and applicable local rules affecting discovery scope
Method for privilege log compliance and attorney-client privilege screening
Specify company-provided mobile devices, BYOD policies, and custodian devices to include in metadata requests
Required format and structure for the discovery request list output
Identify specific facts supporting relevance vs. burden under Rule 26(b)(1) for expansive Slack/mobile requests