General Discussion

In General. Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in
controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable.

On motion by a party or by the person from whom discovery is sought, and for good cause shown, the court in which the action is pending may make any order to
protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense that justice requires,