At a recent discovery conference, opposing counsel asked why I wanted ESI produced in native and near-native formats. Her question struck me as curious. She intended to work with native formats to perform her own review. But when it came time to produce the gigabytes of e-mail, productivity documents, spreadsheets, and database exports, she meant to convert everything to .tiff images. “Where electronically stored information is concerned,” I thought, “lawyers make the Amish look wired.”

Still, “why native?” was a fair question. Assuming she’d commit to capture certain metadata fields, expose tracked changes before imaging, and produce load files with extracted text, we could make .tiff images work for everything but spreadsheets and databases.

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