I received an email from a partner, who had received a draft document for review. Here is the language sent for review in response to a document request:
"Responding Party conducted a diligent search to produce the requested documents insofar as they relate to the subject matter of this litigation and insofar as they are not invasive of the attorney-client and attorney work product privileges, if any exist and are in the possession of responding party which are not subject to any privilege and which do not reflect proprietary, trade secret or confidential information, and insofar as the term “communications” is meant to refer to letters or e-mails. Responding party is unaware of any additional documents responsive to this request other than those attached."
The email said simply this:
"Really? You couldn’t just say we conducted a diligent search and could find no non-privileged documents responsive to the request? Oy vey."
Oy vey says it all.