lays the scope of discovery, whereby parties may obtain discovery regarding any non-privileged matter that is relevant to any party’s claim or defense. Under this rule, a responding party should produce electronically stored information that is relevant, not privileged, and reasonably accessible. Rule 26(b)(2) applies when a party sufficiently proves to the court that certain electronically stored information is not reasonably accessible because of undue burden or cost, that party may not be required to produce that information. However, the court may order such party to disclose such electronically stored information