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Federal Rule of Civil Procedure 26(b) governs the appropriate scope of discovery in federal litigation. In December 2015, the Supreme Court amended Rule 26(b) to emphasize the proportionality factors that had been previously tucked away in subsection (b)(2) and were often overlooked by courts and litigants. The amendment also added consideration of “the parties’ relative access to relevant information” to the list of proportionality factors. As amended, Rule 26(b) now states in relevant part:


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