“At the status conference before the Special Master, the Plaintiff suggested that the dates put forth in the Draft Case Management Plan were unlikely to prove feasible in terms of both the likely start of the document flow and the man-hours necessary to review more than 11,000 pages or documents,” Trump’s lawyers wrote.
“The problem is compounded by the fact that when Plaintiff’s counsel referred to either 11,000 pages or even 11,000 documents during the status conference (we are still awaiting the transcript), the Government chose not to interject with an accurate number. In conversations between Plaintiff’s counsel and the Government regarding a data vendor, the Government mentioned that the 11,000 documents contain closer to 200,000 pages,” the lawyers said.
Trump’s lawyers argued the timeframe given to scan the documents is too narrow.
“In short, seasoned IT professionals who routinely work on large-scale document productions with the Government cannot meet the Government’s proposed schedule, and it was never realistic for the Government to suggest such a narrow timeframe. Consequently, the Plaintiff respectfully suggests that Your Honor and the parties will be best served by having the retained vendor convey a supportable timeframe for scanning roughly 200,000 pages into a platform, and also provide a breakdown of rollout quantities and proposed deadlines.” the lawyers said in Wednesday’s filing.
“It would be better to base deadlines on actual data and not wistful claims by the Government.” they said.