This really happened recently. I was having a Rule 26(f) conference and, as I am supposed to, I said the words (gasp) e-discovery. The response? The response was to suggest that they were already contemplating that I would be asking for far more than what is reasonably necessary and that they already anticipated there would be problems.
So they were objecting before the discovery was even served at the mere mention of the word "e-discovery"? Do they already have the response to my first motion to compel drafted? (Perhaps I should serve such a motion to compel with the requests and streamline the whole process).
No doubt this is the strategy many will employ, but believe it or not, in some cases, the issues are fairly discreet, the list of players reasonably short, and e-discovery is not that hard. Let's all remember to object in good faith.