In Edelen v. Campbell Soup Co. et. al., 2009 U.S. Dist. Lexis 114893 (N.D. GA Dec. 8, 2009), Senior District Court Judge J. Owen Forrester overruled plaintiff's objections to the magistrate judge's order directing plaintiff's counsel to pay defendants' attorney's fees related to narrowing the scope of plaintiff's electronic discovery requests. 

Plaintiff filed an employment discrimination case against defendants.  The court noted that discovery in the case was very contentious with nearly 160 docket entries.   Plaintiff's counsel propounded overly broad discovery, but failed to meaningfully meet and confer regarding the burden and expense of his requests. For example, plaintiff requested the electronic production of his entire company-owned laptop, as well as the entire contents of laptops of numerous other "key players." 

Defendants sought sanctions and the magistrate judge, granting sanctions, in part, ordered plaintiff's counsel (and not plaintiff) pay defendants' attorney's fees incurred as a result of plaintiff's failure to narrow his requests for electronic discovery. If plaintiff failed to narrow his request, the court, in turn, would bar plaintiff from any Rule 30(b)(6) or additional discovery. Plaintiff objected.

The district court overruled plaintiff's objections and found that a blanket request for the complete contents of the laptops of numerous company executives was a fishing expedition and not a request geared to lead toward the discovery of admissible evidence.  Judge Forrester also ruled the request was overbroad on its face.