Extract from Josh Gilliland's article "Printing ESI & Scanning It Is Not OK"
In Indep. Mktg. Group v. Keen, the Defendant-Requesting Party requested the corporate Plaintiff conduct targeted searches with specific key words on specific custodians on the Plaintiff’s server. Indep. Mktg. Group v. Keen, 2012 U.S. Dist. LEXIS 7702 (M.D. Fla. Jan. 24, 2012).
The Plaintiff produced one multiple page PDF without any searchable text or metadata. Indep. Mktg. Group., at *2.
The Defendant requested the Plaintiff do a reasonable search on their server for responsive ESI. The Plaintiff responded by producing four “poor quality” PDF files without any search text. The PDF’s were hundreds of pages long. Indep. Mktg. Group., at *2.
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