In Siriano v. Goodman Manufacturing Co., No. 14-CV-1131 (S.D. Ohio Dec. 9, 2015), the district court granted a motion to compel the production of voluminous documentary discovery (including e-discovery) under the newly revised Fed. R. Civ. P. 26(b)(1).  The court held that “restoring proportionality is the touchstone of revised Rule 26(b)(1)’s scope of discovery provisions.”  The court then analyzed the document requests according to the factors set out in Rule 26(b)(1), including “the parties’ relative access to relevant information” and “whether the burden or expense of the proposed discovery out-weighs its likely benefit.”  The court held that the Rule 26(b)(1) factors favored permitting the discovery here because, for example, “the discovery sought by Plaintiffs is directly relevant to their claims,” “[i]t is highly unlikely that Plaintiffs could discover similar information from another source,” and the information sought was “easily accessible to Defendants but almost completely inaccessible to Plaintiffs.”  The court was “mindful that Defendants’ discovery costs could be significant,” but, the court held, “merely expensive or time consuming” discovery is not necessarily “unduly burdensome.”  The court further noted that “Defendants have not proposed alternative methods of discovery enabling some lesser degree of production, such as limiting the search to certain offices or files.”