TIP Tech sends a request to produce to Behemoth asking for all emails sent between Tyler, Inez, and Paulo using their work email accounts for the last three months they were employed at Behemoth. In response, Behemoth sends hundreds of boxes containing printouts of the millions of emails written by Tyler, Inez, and Paulo, as well as hundreds of other Behemoth employees, starting from the beginning of the company, in a completely random order. Sorting through it would cost TIP Tech many thousands of dollars in attorneys$$ fees. In exceptionally abusive situations like this, TIP Tech could probably ask the court to force Behemoth to provide a more appropriate response to the request to produce.

Why would it be wrong to swamp the opposing party with meaningless documents if they$$re the ones suing you? Is there a line between being adequately responsive to a discovery request and putting your secrets front and center for your opponent to see? If so$,$ how do you toe that line? How could you prevent requests to produce from being used to obtain trade secrets or other confidential information?