- imposed on deps by r30
- imposed on request for admission by r36
- ct may alter above. 26(b)(2)(A)
party need not reveal esi if would be an undue burden/cost. But ct may order for cause. 26(b)(2)(B)
- court must limit under 26(b)(2)(C)
- unreasonably cumulative or duplicitive, or can be obtained from other source(i)
or party has already had ample opp (ii)
or burden outweighs benifit (iii)