Rule 26(b)(1) permits parties to “obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense” and proportional to the scope of the case. Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case.“[T]rial courts retain broad discretion to limit and manage discovery under Rule 26.” Geiger v. Aetna Life Ins. Co., 845 F.3d 357, 365 (7th Cir. 2017).
There are three situations in which a deponent may not answer a question: (1) when it is necessary to preserve a privilege; (2) when the Court has imposed a limitation; or (3) when the party intends to file a Rule 30(d)(3) motion. See Rule 30(c)(2). A Rule 30(d)(3) motion may be filed to terminate or limit a deposition if it is conducted in bad faith or if it is conducted in a manner that “unreasonably annoys, embarrasses, or oppresses the deponent or party.” See Rule 30(d)(3).