New Bad Idea: Claiming You Can Produce ESI as PDF’s because “Native File” is “Ambiguous”

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Courts are not tolerating parties who play games such as “I don’t know what you mean by ‘native format’?” Electronically stored information is part of everyday life with people using Droids and sending mobile Facebook updates. While there will always be gamesmanship in litigation, claiming “native format” is an undefined term is like asking, “what do you mean by ‘paper’?”

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