I get subpoenaed from time to time, not as a party, and it’s unusual if the subpoena doesn’t demand production of evidence not in my possession. So, that’s part of my production, “I don’t have that.” Total non-issue. It’s weird that this response complains about difficulty, “hours of time to review, blah blah blah,” just give the requester everything, and make them review it. Automakers do similar, giving CD’s full of “everything they have,” and they don’t do so out of spite or to bury evidence, it’s just not fair to make them both produce and search against a specific request for evidence, across hundreds of lawsuits.
Why shouldnt DC just have a stack of DVDs to hand out to interested cliential?
Somehow,Broden got something from Twin Peaks.