(b) The Board may limit the type, frequency, extent, and scope of discovery. In doing so, the Board may generally consider whether:
- (1) The discovery request is unreasonably cumulative or duplicative, or is obtainable from some other more convenient, less burdensome, or less expensive source;
- (2) The party seeking discovery has had a reasonable opportunity to obtain the information sought; and
- (3) The discovery request is relevant and proportional to the needs of the case, considering, among other things, the amount in controversy, the parties' resources, and the importance of the issues.