"[T]he ability to obtain relevant information presumes a proper inquiry. Discovery requests require some tailoring. If parties go too far, the courts may whittle down their discovery requests . . . ." Kuehne & Nagel, Inc. v. Preston, Skahan & Smith Int'l, Inc., No. M1998-00983-COA-R3-CV, 2002 WL 1389615, at *3 (Tenn. Ct. App. June 27, 2002). To this end, parties may file motions for protective orders, and the trial court may, for good cause shown, "make any order which justice requires to protect a party . . . from annoyance, embarrassment, oppression, or undue burden or expense, including . . . (1) that the discovery not be had; (2) that the discovery may be had only on specified terms and conditions, including a designation of the time or place . . . ."
Accordingly, the courts can and should actively discourage overburdensome discovery. . . .Kuehne Nagel, Inc. v. Preston, Skahan Smith Intern., Inc., No. M1998-00983-COA-R3-CV, 2002 WL 1389615, at *3 (Tenn.Ct.App. June 27, 2002). The rules favor discovery.
For that reason, excluding relevant evidence is an extraordinary step that courts should employ sparingly. Kuehne Nagel, Inc. v. Preston, Skahan Smith Int'l, Inc., No. M1998-00983-COA-R3-CV, 2002 WL 1389615, at *5 (Tenn.Ct.App. June 27, 2002) (No Tenn.R.App.P. 11 application filed); Richardson v. Miller, 44 S.W.3d 1, 21 (Tenn.Ct.App. 2000). It is important to note that Tenn. R.Civ.P. 26.02(1) allows parties to discover the identities of persons having knowledge about a case's facts, but the rule does not require a party to designate its trial witnesses.