Reasonable Inquiry – Bow Tie Law

Missing One Email in a Production is Not Grounds for a Default Judgment

October 28, 2025 Josh Gilliland Motion to Compel, Request for Production

There is a universal truth in discovery: perfection is not the standard for discovery responses. This does not mean producing parties can throw caution to the wind for their Rule 26(g) obligations that a discovery response is complete and correct after a reasonable inquiry. However, one missing email is not[…]