Marfork Coal Company, Inc. v. Smith
United States District Court for the Southern District of West Virginia
274 F.R.D. 193 (2011)
Marfork (plaintiff) sued environmental protesters, including Nitchman (defendant), who trespassed to protest mountaintop coal mining, seeking compensatory and punitive damages for property damage; during her deposition, Nitchman admitted liability on behalf of the named defendants, but Marfork's counsel also sought the names of other, unnamed individuals who may have participated in the trespass. Nitchman's attorney objected and requested a stay pending a district court ruling on whether she was required to answer.
Whether a district court may impose limitations on the frequency or extent of discovery sought within the scope of Federal Rule of Civil Procedure 26(b)(1).