The issue of production format when dealing with ESI is often the subject of discussion and disagreement.  If possible, the parties to the litigation should agree at the outset to the production format.   In fact, a conversation about production format, metadata and redactions (among other things) should occur at the preliminary conference and/or the Rule

In a recent decision out of Oklahoma (Curtis v. Progressive N. Ins. Co., No. CIV-17-1076-C [W.D. Okla. June 13, 2018]), District Judge Robin J. Cauthron ruled that non-party ESI subpoenaed pursuant to Rule 45 was not subject to the 100 mile-limitation found in the Rule.  Specifically, the Court held there is “no violation

Traditional document review can be one of the most variable and expensive aspects of the discovery process.  The good news is that there are innumerable analytic tools available to empower attorneys to work smarter, whereby reducing discovery costs and allowing attorneys to focus sooner on the data most relevant to the litigation.   And, while various