As every TCPA class action lawyer knows, the primary strategy of the Plaintiff’s bar is to serve massively overbroad discovery demands to put enormous pressure on the Defendant to settle for millions of dollars.
No company wants to be turned inside out and have its confidential–and often extremely sensitive consumer financial information- turned over to a plaintiff-side “expert” that will probably store it on a thumb drive in his kitchen junk drawer.
As I explained not long ago, a good set of objections to the typical shotgun style discovery demands TCPA class counsel serve should span over a hundred pages. And failing to properly articulate objections–and support them with suitable evidence in opposing motions to compel–can lead to terrible results.
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