Sexton v. Lecavalier, 11 F. Supp. 3d 439 (S.D.N.Y. Apr. 11, 2014)

Key Insight: Court declined to hold third party in contempt where failure to produce Gmail in native format was result of good faith (but mistaken) belief that Gmail emails cannot be produced in native format; opinion noted options for production of Gmail emails in native format

Electronic Data Involved: Gmail emails