Regardless of what you call them—clone, copycat, flipped—the request is the same: to re-produce document productions from a prior matter to a different party in a new, related matter. Often, the presumption is one of relative ease—just produce what you did before. Such requests, though, often disregard both the potential procedural complexity of clone discovery and the relevance, proportionality and particularity requirements of discovery under the Federal Rules of Civil Procedure.