Question: Answer the below question by writing one paragraph: ESI Protocols: Plaintiffs propose a broad keyword search list including patient names and internal terms like flagged

Answer the below question by writing one paragraph:

ESI Protocols: Plaintiffs propose a broad keyword search list including patient names and internal terms like "flagged account," which may return thousands of irrelevant results.

What negotiation strategies would you suggest to refine or challenge this search criteria?

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