The demands for internal memos aren't arbitrary, they follow due process of law. Plaintiff serves a subpoena. Defendant can contest the subpoena by filing a motion to quash with the judge, who either approves or denies the motion. But in a case like this where the defendant is a large corporation (or representative thereof) and the subpoenaed information is relevant to the facts of the case, the judge is likely to honor the subpoena.