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A Practical Primer On Production Format Requests

BY Helen Geib
September 02, 2015

The electronic format that electronically stored information (ESI) is produced in is a necessary component of e-discovery. This article offers a primer on production format issues by diagramming a template request in order to explain both the technical meaning and practical significance of the terms.

Too many litigators take a hands-off approach to production format requests. Some delegate writing the request to litigation support staff or the e-discovery vendor. Others reuse the same generic template in every case, while some lawyers even try to avoid the issue altogether by leaving the production format to the opposing party's discretion.

At first glance, the technical language used in production format requests might seem to justify at least the first of these approaches. It's certainly true that it's important for lawyers to collaborate with their technical support team in drafting format requests. It's critical that the production meet the technical specifications of the document review database. In addition, e-discovery professionals are a valuable knowledge resource in dealing with non-standard ESI data types. In a similar vein, templates are a convenient, time-saving tool when properly used as a starting point for drafting a request.

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