The form of production is a lot like ordering a pizza: say what you want. Thin crust, sauce, topping. All are things you can order.
Requesting electronically stored information is exactly the same. You can request native files and types of metadata just like you are ordering a pizza. You could also request static images with specific fields of metadata. It does take a little longer to process than 30 minutes.
RPM Pizza, LLC v. Argonaut Great Cent. Ins. Co., drives home this point literally and figuratively.
Magistrate Judge Stephen C. Riedlinger understands the mechanics of how to request the form of production. In this case, the Producing Party (Argonaut) challenged the Requesting Party’s (Domino’s) stated form of production with the argument the Requesting Party had not shown why it was “necessary…to produce in a format that complies” with their production instructions. RPM Pizza, LLC v. Argonaut Great Cent. Ins. Co., 2013 U.S. Dist. LEXIS 165200, at *12-13 (M.D. La. Nov. 15, 2013).
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