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Courts have recognized the perils of discovery on discovery and have sought to regulate the practice to prevent the “danger[s] of extending the already costly and time-consuming discovery process ad infinitum.”  Am. W. Bank Members, L.C., 2021 U.S. Dist. LEXIS 218480, at *5. As a baseline, many courts have held that failure to show

We can’t go on together with suspicious minds”—that is the premise of “discovery on discovery.” With suspicion on the mind, a party may believe that its opponent has wrongfully withheld information, documents, or other materials in discovery, and therefore may seek to have discovery on discovery. Discovery on discovery, also referred to as