You asked:...

"So, is this looking to be in our favor at this point?"...

Here is your ANSWER...

26(c). Indeed, Rule 26(c) requires the filing of a motion for protective order and provides that

“the movant must certify that it has in good faith conferred or attempted to confer with the other affected parties in an effort to resolve the dispute without court action.” Fed. R. Civ. P. 26(c).

Defendants do not dispute that they have not sought to meet and confer with e.Digital regarding the reasonableness of its discovery requests or the purported burden or expense of any proposed electronic discovery.

"As set forth above and in e.Digital’s Motion, the Magistrate Judge’s marked departure from the now well-settled procedure in Rule 26 on an empty record was unjustified and cannot stand. An appropriate modification of the Amended Scheduling Order is warranted under the circumstances."...

That is the nicest way in saying "The Hon. Magistrate Judge erred and his ORDER should be modified is prayed for herein."...

Gil...