Three turns and a check. Keep this open next to your chat: each step is the thing to paste next, with what you typed already carried across. Nothing is sent from here, and nothing on this page is a transcript. The conversation stays where you are having it.
Paste the full set including the definitions and instructions.
The claims, defenses, and the time period actually in issue.
The forum and any ESI protocol or stipulation already in place.
Your client and their position in the case.
The systems, volumes, and anything already produced.
Watch for, the whole way through
Boilerplate objections have drawn sanctions and waiver findings in many courts. An objection that does not state its grounds with specificity can forfeit the objection entirely.
Failing to state what is being withheld under an objection is its own violation in many forums, separate from the objection's merits.
The model cannot know your client's data volumes or system capabilities. Every burden objection has to be backed by a number somebody at the client provides.
Proportionality practice, the form of objections, and response deadlines vary by forum and by judge. Confirm each before serving.
Do not paste privileged material or client-confidential documents. The requests and a description of the client's systems are enough to draft from.