(1) Scope in General. Unless otherwise limited by court order, the scope of discovery is as follows: 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, considering
– the importance of the issues at stake in the action,
– the amount in controversy,
– the parties’ relative access to relevant information, the parties’ resources,
– the importance of the discovery in resolving the issues, and
– whether the burden or expense of the proposed discovery outweighs its likely benefit.
Information within this scope of discovery need not be admissible in evidence to be discoverable.