In Cargill Meat Solutions Corp. v. Premium Beef Feeders, LLC, No. 13-cv-1168-EFM-TJJ, 2015 WL 3937410 (D. Kan. June 26, 2015), the court considered the defendants’ motion to compel and the plaintiff’s objection that the cost of producing the requested materials was unduly burdensome and outweighed the benefit of the discovery.  The court held that to prevail on its proportionality objection, a party must “provide sufficient detail in terms of time, money and procedure required to produce the requested documents.”  The court held that the plaintiff failed to meet that burden because the only evidence the plaintiff provided was an “estimate” that complying with the defendants’ request would cost between $4,000 to $5,000 per custodian.  The plaintiff did not identify the custodians or explain how many custodians would be involved and failed to explain why this cost would be disproportionate to the amount in controversy, which was in excess of $2 million.