In ongoing e-discovery dispute, the plaintiffs complained that the defendant, among other things, improperly converted documents from their original format, which had been searchable and sortable, into PDF files, which did not have these capabilities. Quoting the 2006 Advisory Committee Notes, the court found that Defendant “violated Rule 34 in producing documents which were not searchable or sortable. As a result, their argument that plaintiffs did not request the documents in native electronic format or that the court’s order did not require this format, fails.” See L.H. v. Schwarzenegger, No.06-2042, 2008 WL 2073958 (E.D.Cal. May 14, 2008).
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