Piercing the Work Product Doctrine: Gamesmanship with Locked PDF’s


The Plaintiffs in Mack v. HH Gregg, Inc. sued the Defendants for breach of contract over the alleged failed installation of dryers.

The parties agreed the Defendants would produce a “summary of its dryer installation invoices that would include the state of the sale, date of purchase, amount paid for delivery and installation, and the make and model of dryer purchased.”

The Defendants in turned produced an 11,757 page “locked” PDF summary for the Plaintiffs.

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