In re Methodist Primary Care Grp, 553 S.W.3d 709 (Tex. 14th Dist. Ct. App. June 21, 2018)

Key Insight: 3rd party access to another entity’s electronic database. On appeal, discovery order vacated on four factors: inadequate data request, no evidence that search would find responsive data, order requested data outside plaintiff’s original request, order improperly granted access to data outside litigation’s scope.

Nature of Case: Trade secret theft and interference with patient relationships

Electronic Data Involved: electronic practice management systems in the cloud

Keywords: 3rd party, expert, search, electronic database, cloud, undue intrusion, beyond the scope.