Braxton v. Farmer’s Ins. Group, 209 F.R.D. 651 (N.D. Ala. 2002)
Key Insight: Non-party subpoena issued by plaintiff to insurance agents for email and electronic documents touching on, relating to or concerning use of consumer credit reports in setting homeowners’ insurance premiums quashed as unduly burdensome, in absence of showing that defendant’s production of such materials was inadequate
Nature of Case: Class action alleging that insurer violated Fair Credit Reporting Act
Electronic Data Involved: Email and documents in electronic format