When Celerity’s law firm client sued a large bank on behalf of homeowners for violating federal mortgage regulations, it requested data and documents related to the Home Affordable Modification Program. The defendant objected, claiming that the burden and expense of the proposed discovery outweighed its benefit. Our law firm client believed that the bank inflated the cost of plaintiffs’ request but required a better understanding of industry standards to make the counterargument. Celerity was engaged to provide this knowledge. By examining market rates and fees charged to similar clients, we prepared an affidavit of expert opinion estimating the total cost of collection, review, and production. Our work provided the client with the information necessary to invalidate the bank’s claim.