Greenberg v. Hilton International Co., 875 F.2d 39 (2d Cir. 1989) (full-text).
Appellate Court Proceedings
|“||[R]equests for costly statistical compilation useful only for professional analysis should be accompanied by reasonably precise representations as to counsel's intentions with regard to preliminary analysis and to retention of an expert. Those resisting such discovery can then be given the option of producing only that data necessary to preliminary analysis with more elaborate production to follow if the preliminary analysis indicates that more sophisticated examination would be useful.||”|
- 875 F.2d at 42.