When Reynolds Alley (plaintiff) inflated his snowblower tire, the rim exploded, injuring Alley’s hand. After $6,000 in medical bills, Alley sued the manufacturer, MTD Products, Inc. (MTD) (defendant), for $100,000 in damages. MTD produced information from prior cases involving the same model, including the claimants’ and attorneys’ names and where the cases were filed. MTD’s counsel said most of those lawsuits involved similar injuries from exploding tire rims. MTD also produced product recall records that showed knowledge of the defect. Alley’s attorney nonetheless asked MTD to produce all documents from the prior lawsuits, including expert reports, deposition transcripts, and discovery. Alley’s attorney also filed a Rule 30(b)(6) notice to depose MTD’s records custodians, seeking their identities, and to question them about nine listed topics about MTD’s document storage and retrieval systems. MTD requested a protective order to prevent the additional discovery and submitted an affidavit from its national discovery counsel explaining that the costs would likely exceed $100,000. Alley’s attorney countered that he needed the additional discovery to prove MTD’s knowledge and recover punitive damages and that its production would not unduly burden MTD.