I was drafting discovery this week, and it just struck me as odd that I could totally make up whatever definition I wanted for certain words to be used in my requests and their responses.
The case that I was working on involved an agricultural product that I know virtually nothing about. (Well, I know much more than the average person and much less than the average farmer.) But I needed to define the product. And there is no "Dictionary of Agricultural Terminology" sitting in my library. So I making shit up to define what I think this product is.
But it gets trickier than that--because you can't be too narrow in your definition, or your opponent will decide that he doesn't have to reveal everything. This I know, because I got some of those narrowly defined discovery requests a couple of weeks ago. And there were several documents my opponent didn't get because of the narrowness of their request.
I guess I'll see how my definition worked out when I get the responses back.