In this products liability motion arising from a fractured artificial hip stem, the plaintiffs sought refusals and undertakings following discovery of the corporate defendants.
The court held that electronically stored information in a database is discoverable and that the defendants could be ordered to run a broader query, but only within proportionate limits tied to the pleaded design, manufacturing, and failure-to-warn issues.
The court ordered disclosure of fracture incident data for specified similar models and time periods, required clarification of database filters, and directed limited follow-up inquiries regarding a technical article, product durability, and x-ray issues.
Broader requests concerning historical testing methodologies, supplier selection, and general training were refused as disproportionate or unsupported by the pleadings.