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After a lawsuit is filed in federal court, one party asks for a ruling that would change how the case proceeds. A party demanded all internal emails and counsel notes for a modest damages claim. The parties disagree about the legal effect of those facts. Which answer gives the best resolution?

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Reject the claim or defense solely because the opposing party disputes a required fact. The court should decide the procedural request by applying the operative rule to the record: Discovery must be relevant and proportional, and privileges, work product, protective orders, sanctions, and burdens limit otherwise discoverable information. Resolve the dispute on equitable fairness alone without identifying the governing doctrine or its limits. Assume the doctrine applies because one element appears satisfied, even if the remaining elements are contested.

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