Jackson v. AFSCME Local 196, 2008 WL 1848901 (D. Conn. Apr. 25, 2008)

Key Insight: Where nonparty stated that in-depth electronic search would need to be conducted in order to produce responsive documents, thus resulting in substantial cost to nonparty, court ordered nonparty to provide plaintiff with estimate of cost and explanation of fees, with copy to court, before embarking on search so plaintiff could decide whether she wished nonparty to proceed; court further ruled that plaintiff must pay nonparty’s compilation fees before delivery of documents to plaintiff

Nature of Case: Union member alleged that union breached its duty of fair representation

Electronic Data Involved: Unspecified ESI