In case where party “essentially requested all of defendants’ electronically stored information” which is “the e-discovery equivalent of requesting all of defendants’ filing cabinets,” Judge Adelman noted that “in some circumstances it may be appropriate to allow a requesting party direct access to a responding party’s electronically-stored data, such as where the court has cause to believe that a responding party has concealed information or lacks the expertise necessary to search and retrieve all relevant data, including metadata or residual data.” However, in the absence of such a showing, the motion to compel was denied. Henderson v. U.S. Bank, No.08-0839, 2009 WL 1152019 (E.D.Wis. April 29, 2009).
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