Over the years, more than one defense counsel has uttered in disgust during discovery, “That plaintiff requested everything but the kitchen sink,” as her e-discovery team began to organize, discover, and produce responsive electronically stored information.

However, in 2018, large corporate defendants aren’t the only ones with big data. Even solo personal injury litigants create substantial stockpiles of electronic data, and plaintiffs aren’t the only ones making broad e-discovery requests—as one litigant learned recently after dining at Denny’s, alleging injury, suing the restaurant chain, and getting discovery requests for everything from her Facebook account to her Fitbit data.

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