This section contains the nature of the case and procedural background.

Ps made broadly worded discovery requests that were not reasonably particularized. P's counsel has tried to collaboratively develop ESI protocol for proportional discovery. D insists that it is justified in refusing to engage in basic ESI discovery or to do so promptly because they lack enough resources and manpower. Ps allege that the budgeting methodology of D violates parts of the Medicaid Act, 42 U.S.C. § 1396a; the Americans with Disabilities Act (ADA) 42 U.S.C. § 12132; § 504 of the Rehabilitation Act, 29 U.S.C. § 794; the Michigan Mental Health Code, Mich. Comp. Laws § 330.1722; and Michigan's Medicaid Habilitation Supports Waiver. The court found Ps' claims under the Medicaid Act viable, focusing largely on allegations that the new budget methodology would cause home isolation. Ps have stated a plausible claim for violation of the integration mandate under Title II of the ADA and § 504 of the Rehabilitation Act.' Id. at 464. A scheduling conference was held and Ps had already served third-party Washtenaw County (D) with a subpoena for documents; third-party Health Management Associates (HMA) with a subpoena for documents about the Community Living Supports (CLS) program area at D and its predecessor organization; and a first set of interrogatories and requests for production of documents on D. In June and July 2021, competing motions about these discovery requests followed, and Judge Tarnow referred the motions to this Court for hearing and determination. After an extensive hearing and findings, Ps and HMA filed a joint statement saying that HMA identified documents responsive to the subpoena served on it and agreed to produce them when the Court issued an order overruling its confidentiality objection. Ps, D, and the County (D) made some progress during their meet and confer after the September 2021 hearing, but significant disputes remained.

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