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David Lapresi said:
Craig, as mentioned in your articles and blogs, I thought I would share this actual response and a very typical response and push back when asking for Natives.
I would also like to discuss further the production of documents in true native format. While we would agree to produce in native format files such as Excel spreadsheets that are not useful when converted to Tiff, we have several concerns with producing all documents in true native format. First, when producing in Native, the integrity of the documents we produce is not secured and the documents can be easily altered. If we produce in native, how would you propose ensuring that documents later used in the litigation have not been altered? Second, it is our experience that documents produced in native are very difficult to keep track of as a practical matter because each page number is not separately identified. This becomes particularly difficult when documents are used for depositions, summary judgment motions, and trial exhibits.
When producing in Tiff format we would provide metadata to identify the family grouping of email or any other family relationships to reproduce how documents were kept in the regular course of business. If there are particular metadata fields you are concerned about, please let us know and work together on providing the fields requested.