The concept of exporting might conjure up images of large shipping crates hoisted aboard ships or wheeled through the cargo bay doors of humongous transoceanic aircraft. What likely doesn’t come to mind is that invisible place where you back up your computer. But if you are saving data on a cloud...

In case you were in doubt, being asked to provide “easily accessible” digital records of thousands of paper documents you already produced may not be considered unreasonably cumulative, duplicative or burdensome, and if the related costs are something like .025% of the amount in controversy...