Cases these days seem to involve more paper than ever. While detailed documentation may generally be a good thing, it has also resulted in an additional seat at the deposition table just for all the documents. A decade ago you could walk into a deposition with a large binder full of documents and remain confident that you had every possible document that you might need for the deposition. Now, such assurances consist of several bankers boxes full of documents.
These bankers boxes of documents brought to a deposition seem to take on a life of their own. After we have diligently identified every last document, we spend hours printing them and making copies for every last person sitting at the deposition table. Then we painstakingly try to organize them in what we believe to be a chronological order. Once at the deposition you begin with everything neatly organized, then by the end you have skipped all over your outline and, if you were lucky, you were able to find all of the documents.
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