[cycomanic]

>You are assuming that they have this information. However their argument is that the search terms "could" retrieve such documents. There is nothing here that confirms they possess these purportedly irrelevant documents that would be produced given the current search terms.

Having the documents is a necessary condition to them being found (or in other words if they don't have the documents they can not be found), so I would hope making such an argument without actually having any documents containing this information would get them a stern talking to by the judge. Then again law often works very different to what we laypeople assume.