The defendant was a dissolved fashion technology startup that had gone through an assignment for benefit of creditors — the corporate equivalent of an informal liquidation. No active employees remained. Corporate records were scattered across former executives, personal email accounts, and cloud storage services with expiring credentials. The plaintiff alleged exempt misclassification, unpaid overtime, missed meal and rest periods, and wage statement violations. The 121-page discovery response to 92+ document requests was designed not merely to comply with discovery obligations but to affirmatively build the exempt classification defense into the document production framework itself. Each objection anticipated the specific certification motion arguments the plaintiff would later make. The document index cataloged 90+ responsive documents by Bates number with explanatory parentheticals connecting each document to a specific defense theory — job duties analysis for the administrative exemption, salary basis documentation, discretion and independent judgment evidence. The production told the defense story before the defense was formally asserted.