Plaintiff brought a motion to compel based on a date change (from 2005 to 2009) in a memorandum, and the absence of records memorializing meetings and discussions referred to in other discovery materials. The court held that plaintiff could, at its own expense, hire an expert to verify the completeness of the defendant’s production, based upon the access to and review of a sample of five backup tapes. Kilpatrick v. Breg, Inc., 2009 WL 1764829 (S.D.Fla. June 22, 2009).