Although we have a "default standard" for discovery in DE, there's a lot of leeway for deviation based on the facts of the case. More (or fewer) custodians, more (or less) metadata, search terms that call eldritch horrors from their squalid caches -- pretty much anything is on the table.
There's always a line somewhere, and I think we found it last week in Acceleration Bay, LLC v. Amazon Web Services, Inc. C.A. No. 22-904-RGA-MPT (D. Del. Nov. 22, 2022). The defendant, AWS, wanted to include the following passage in the ESI Order:
Acceleration Bay shall not seek email discovery relating to infringement or damages, except that Acceleration Bay …