In Armstrong Pump, Inc. v. Hartman, No. 10-cv-446 (W.D.N.Y. Dec. 9, 2014), the court considered discovery disputes in a case that was more than four years old and for which “discovery [was] far from complete.”  The court faulted the parties for “piecemeal discovery and excessive delay.”  In response, the court announced that it would “fashion a new and simpler approach to discovery,” which consisted of 13 key-word terms that the plaintiff would be required to search for on “all corporate documents, files, communications and recordings.”  The plaintiff would be required to “maintain a list of every server, computer, file room, or other place searched, and a list of all positive search results.”  “When the search is complete, a representative of [plaintiff] and all of [plaintiff’s] counsel of record will file a sworn statement confirming that [plaintiff] made a good faith effort to identify sources of documents; that a complete search of those sources for each of the above phrases occurred; and that the search results have been furnished to [defendant].”  The court required that the plaintiff complete this search within four months “with absolutely no exceptions or extensions.”