Q: My attorney has requested documents/information from me to produce in discovery. What should I disclose?
A: You should disclose everything that is requested. Even if the information contains information you believe is irrelevant, privileged, contains trade secrets, etc., you should still disclose that information. Your attorney will go through the documents to flag documents that are not discoverable and should not be produced to the opposing party. If you are concerned about the disclosure of certain documents, call your attorney to discuss the specific documents you have concerns about so the attorney can include the basis for non-disclosure in a privilege log or mark the document as confidential material.