In United States v. University of Nebraska at Kearney, No. 11-cv-3209 (D. Neb. Aug. 25, 2014), the district court denied a motion to compel seeking a broad search of the defendants’ electronic systems to find all documents related to any complaint of discrimination.  The court held that the requests sought non-relevant information (because they sought information outside of the type of conduct alleged in the case) and because the searches would impose a disproportionate burden that would outweigh their likely benefit pursuant to Fed. R. Civ. P. 26(b)(2)(C)(iii).  Instead, the court held that traditional forms of discovery would be better suited to locating the information the plaintiff sought:  “Searching for ESI is only one discovery tool.  It should not be deemed a replacement for interrogatories, production requests, requests for admissions and depositions, and it should not be ordered solely as a method to confirm the opposing party’s discovery is complete.”  The court placed special emphasis on the fact that there was no evidence “that the defendants hid or destroyed discovery [or] cannot be trusted to comply with written discovery requests.”  The court thus reasoned that the plaintiff could ask questions in depositions and interrogatories that would identify relevant facts, rather than combing through all of the defendant’s computer systems.  As the court explained, “the court is convinced ESI is neither the only nor the best and most economical discovery method for obtaining the information the government seeks.  Standard document production requests, interrogatories, and depositions should suffice – and with far less cost and delay.”