Court Orders Native Production Absent Explanation of Allegedly Burdensome Cost and Upon Showing of Good Cause
Mitchell v. Reliable Sec., LLC, No. 1:15-cv-03814-AJB, 2016 WL 3093040 (N.D. Ga. May 23, 2016)
Addressing the parties’ dispute over the proper format of production—specifically, whether ESI should be produced in native format or PDF—the Court found Defendant failed to make an adequate showing that production of native files was cost prohibitive and that, in any event, Plaintiff had shown good cause, and ordered production of ESI in native format.