[brief] This Court should reverse the ESI Order for an independent reason: it reflects an abuse of discretion.  Under Rule 4:10-2(g), a court must limit even otherwise-permissible discovery if “the burden or expense of the proposed discovery outweighs its likely benefit,” taking into account “the importance of the proposed discovery in resolving the issues. ”  Pereira, 475 N.J. Super. at 393 (quoting R. 4:10-2(g)).  Like the trial court, Plaintiffs entirely ignore Rule 4:10-2(g)’s balancing command, which forecloses the grossly overbroad ESI Order.  First, the trial court’s order is unduly invasive and burdensome.  Not only does it impose monetary costs, Db38-39, but it violates Defendants’ privacy rights, Db36-38, as well as the privacy rights of nonparties whose information might be swept within a production.  Plaintiffs counter that the trial court imposed a discovery confidentiality order, but even if that order successfully prevents Plaintiffs from broadcasting documents publicly—and there is good reason to assume it will not, Db36-37—Defendants are entitled to withhold from an adversary sensitive business documents that have no relevance to the litigation at hand.  Indeed, Plaintiffs seem to recognize the “privacy concerns” involved with allowing parties to search an individual’s electronic devices.  Pb33; see Lipsky, 474 N.J. Super. at 470.  But those same privacy concerns exist when the Defendant must turn over the contents of its electronic devices—that is, the information stored on them—without any relevancy screen.  Second, the trial court identified no countervailing justifications that warrant such intrusive discovery; indeed, it wholly failed to consider “the importance of the proposed discovery in resolving the issues. ”  Pereira, 475 N.J. Super. at 393 (quoting R. 4:10-2(g)).  Neither Plaintiffs nor the trial court suggested that the tens of thousands of irrelevant documents were themselves important to “resolving the issues. ”  Id.  Instead, Plaintiffs view these documents as “unavoidable” collateral damage in their quest to obtain all relevant documents.  Pb20.  But as explained above, this Court has rejected this type of discovery-at-all-costs approach, supra at 8-10, and the trial court was required to try first the “clear alternative[s]” available to the parties and the trial court to maximize the production of relevant documents, Lipsky, 474 N.J. Super. at 473.  Finally, Plaintiffs assert that the ESI Order was imposed merely to address the “particular” and “unusual” record of this case.  Pb18.  But the trial court in fact made clear that its “usual stance in these cases” is to preclude “a relevance type of review. ”  T4:7-12 (emphasis added).  The trial court thus imposed the Order not based on any particularized finding that the parties could not be trusted to produce relevant documents in this matter, but because the Order’s approach is just “the way” the court “do[es] things in these cases. ”  T21:8-9.  Perhaps so, but it is not the way discovery is to proceed under New Jersey law.  Rule 4:10-2(a) explicitly requires a relevance review in e-discovery cases the trial court here did not allow, and Rule 4:10-2(g) explicitly requires a balancing of costs and benefits the court did not conduct.  The ESI Order is thus plainly contrary to law and just as plainly an abuse of any discretion the law may allow.  Unless New Jersey law and practice deviates from the broad national consensus governing modern e-discovery, the ESI Order cannot stand.  CONCLUSION