Coordination. Evidence has to be gathered from several locations, each with its own records and its own timetable, and any inconsistency between them needs reconciling. Where a site is operated by a client or third party, counsel time to assess that arrangement is an additional item.
Budget for gathering, not just drafting
Ask for the collection phase to be scoped separately from the drafting, since the number of sites drives it directly. Decide which locations are central to the showing and document those fully rather than treating every one equally. If the region includes an entity outside the corporate group, raise it before the scope is fixed, because it changes the analysis.
Confirm official charges at the applicable step. Scope the collection phase separately from the drafting, because the number of sites drives it directly and a single quotation covering both hides where the effort actually goes. Evidence has to be gathered from several locations, each with its own records and its own timetable, and any inconsistency between them then needs reconciling.
Decide which locations are central to the showing and document those fully rather than treating every site equally, since equal treatment produces volume rather than weight. Where a site is operated by a client or a third party, raise it before the scope is fixed, as counsel time to assess that arrangement is an additional item.