In Koninklijke Philips N.V. v. Hunt Control SystemsInc., No. 11-3684 (D.N.J. Apr. 16, 2014), the district court granted a protective order precluding a noticed deposition of the plaintiff’s e-discovery consultant.  The defendant contended that deficiencies in the plaintiff’s production required a new e-discovery search using different tools and processes to be explored in a deposition.  The court rejected those arguments, holding that “[plaintiff] has made adequate representations to this Court that its [ESI] approach . . . is reasonable” and several of the alleged deficiencies were “speculative and suggestive in nature.”  The court further held that “[defendant’s] alleged dissatisfaction with the result of [plaintiff’s] search is not enough to reopen the door to the collection of ESI discovery under a completely different method.”  The court also noted that, although the requested deposition itself would not cause a substantial discovery burden, the deposition would likely lead to “opening the door to more (and likely unproductive) discovery with no apparent end in sight,” causing “tremendous burden” to the plaintiff.