Lanard Toys, Ltd. v. Dolgencorp, LLC,
Case No. 3:15-cv-849-J-34PDB (M.D. Fla. January 21, 2016)
The 2015 amendment to Rule 26(b)(1) reinforces the obligations of parties to consider the proportionality factors in propounding and responding to discovery requests. Also, parties that fail to discuss ESI issues at the Rule 26(f) conference may be precluded from later seeking relief from the Court for issues not discussed during the Rule 26(f) conference.