For those of us for whom discovery is just not enough, don't worry—there's also discovery on discovery.  Not surprisingly, discovery on discovery—discovery into the methods a party uses in its discovery processes—is a topic that has generated much disagreement and rancor between parties: either demanding it or refusing it, with a definition that may change based on the circumstances, and how the parties are situated.

In a recent opinion, a court expands the discourse around discovery on discovery—defining it, discussing it, and devising a new framework for considering requests for it.