On the other hand, the vendor costs alone associated with complying with Plaintiff’s

broad discovery demands will put significant, unwarranted economic pressure on each of the

Defendants.

Defendants have not asked the Court to require the requesting party to pay all of the costs

of electronic discovery imposed on the producing party -- only the outside vendor costs. The

internal costs of complying with e-discovery are very significant, both in terms of lost employee

time and internal expense. However, it is only the outside vendor costs that are subject to the

Amended Scheduling Order. Therefore, parties serving requests for production will be

motivated to draft narrowly-tailored requests that focus on documents relevant to the claims and

defenses in this action. In addition, discovery disputes will likely be resolved without Court

Plaintiff may be able to identify a few exceptions where documents produced as a result of

these requests might include relevant information, but the problem is that the vast majority of the

many thousands of responsive documents produced at great expense to the Defendants will have

no bearing whatsoever on the case.