D'Onofrio v. SFX Sports Group, Inc.
United States District Court for the District of Columbia
247 F.R.D. 43 (D.D.C. 2008)
D'Onofrio (plaintiff) sued her employer, SFX Sports Group (defendant), for gender discrimination and wrongful termination, and during discovery requested SFX's business plan using instructions to preserve and identify the files where documents were kept; SFX produced the plan but not in its original electronic format with metadata. D'Onofrio moved to compel production in the original format, arguing Rule 34 required it absent a showing of necessity to use another format.
Whether, in responding to a discovery request, a party must provide electronically stored information in its original format with accompanying metadata unless it is necessary to provide it in a different format.