From Regan-Touhy v. Walgreen Co., 2008 U.S. App. LEXIS 10704 (10th Cir. May 20, 2008):
[T]he burdens and costs associated with electronic discovery, such as those seeking "all email," are by now well known, and district courts are properly encouraged to weigh the expected benefits and burdens posed by particular discovery requests (electronic and otherwise) to ensure that collateral discovery disputes do not displace trial on the merits as the primary focus of the parties' attention.
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