In e-discovery, it is not uncommon to see production requests for a copy of an entire database instead of requests for targeted, relevant information. For example, in the investigation of an age discrimination claim, a party may request a copy of an entire human resources database, instead of asking for specific data relevant to the claim. Many parties incorrectly assume that such broad requests facilitate more complete production and eliminate the risk of inadvertently failing to request a key piece of data.
On the contrary, a full database production may actually omit important data because the database (which stores the data) works in concert with the application (which presents the data to users). In doing so, the application may derive and present data that the database does not store. For example, employee age is a constantly changing target because age is determined, in part, by the current date. Therefore, the application handles calculating and displaying employee age derived from the date of birth (stored in the database) and the current date.
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