Motion for order shifting costs of reconstructive data discovery

[Name]

[Address]

[Phone number]

Attorney for [moving party]

UNITED STATES DISTRICT COURT

FOR THE ___________ DISTRICT OF __________

Civil Action, File Number _________

_____________________________________

)

[Name], ) MOTION FOR ORDER SHIFTING COSTS

Plaintiff, ) OF RECONSTRUCTIVE DATA DISCOVERY ADDITIONAL DEPOSITION(S) )

)

v. )

)

[Name], )

Defendant. )

____________________________________)

[Responding party] moves this Court for an order shifting the costs of reconstructive data discovery from [responding party] to [requesting party]. This motion is made on the following grounds:

Explain argument. The responding party normally pays the costs of responding to a discovery request, such as the cost of copying documents. Moving party must show that the requesting party should bear some or all of the costs of providing the discovery sought. The factors the courts consider in determining whether to shift costs are set forth below. Include all...