In 2007, Caroline Kubicki suffered permanent brain damage when a medical pump delivered too much insulin into her body to treat diabetes. John and Karen Kubicki (plaintiffs), on behalf of Caroline, filed suit in federal district court against the manufacturers of the pump (defendants), including Medtronic, Inc. (Medtronic) (defendant). The Kubickis alleged negligence, breach of express warranties, and strict liability, and sought discovery as to all of the insulin-infusion devices that Medtronic had manufactured since 1999. Specifically, the Kubickis asked Medtronic to produce (1) post-manufacture and post-injury remedial events and measures; (2) communications and interactions with foreign regulatory agencies; (3) sales, market share, and profit information; and (4) adverse events. Medtronic refused to produce the documents, claiming that the pump model Caroline used was very different from earlier and later models and that the information sought was thus not relevant to any claim or defense. The Kubickis filed a motion to compel discovery.