1. Accessible Data Issues Brett Shavers and Allison Goodman

9. Petcou v. C.H. Robinson Worldwide, Inc., 2008 U.S. Dist. LEXIS 13723 (N.D. Ga. Feb. 25, 2008). Pursuant to Fed. R. Civ. P. 26(b)(2)(B), the court found the Defendant met its burden to show that deleted email was not reasonably accessible, as the cost of doing so for only one employee would have been approximately $79,000. Simon Property Group, Inc. v. Taubman Centers, Inc., 2008 U.S. Dist. LEXIS 5065 (E.D. Mich. Jan. 24, 2008).. A non-party objected to a subpoena, however, they failed to do so within the time allowed by Fed. R. Civ. P. 45(c)(2)(B). The court did order the parties involved to make a good faith attempt to narrow the scope of the subpoena, as it was so broad that it would have required 3 employees of the non-party to search servers for approximately 4 weeks.