Wagoner v. Lewis Gale Medical Center, LLC

Wagoner (plaintiff), a security guard with dyslexia, sued Lewis Gale (defendant) under the ADA after being terminated, and sought discovery of ESI from his former supervisors using specific search terms. Lewis Gale's email system retained emails only briefly by default, requiring a costly third-party retrieval process, and it argued the resulting expense made the information not reasonably accessible.

Whether relevant information is undiscoverable if the responding party can demonstrate that it is not reasonably accessible due to undue burden or cost.