I get what you're saying, but in my experience, the risk of sanctions for a good faith production with a few things overlooked is minimal to none. If the other

I get what you're saying, but in my experience, the risk of sanctions for a good faith production with a few things overlooked is minimal to none. If the other side notices and brings it up (assuming nothing else preventing production), you just give it to them. Problem solved. No judge is going to impose sanctions for essentially doing what the rules of discovery tell you to do. In Pao's case, it comes across as allowing the other side all kinds of opportunities to go fishing for irrelevant tangents, embarrassing material, overly-personal material, etc., with an almost passive endorsement of that tactic. She wrote that some of this stuff included attorney-client communications! That's terrible. And one of them was a therapy record? Doesn't that sound like a HIPAA issue? You'd think that effective counsel would try to define the scope of the evidence and the boundaries of the issues on the table every chance they could. A well-thought out document production is one of the cheapest and easiest ways of doing that.