When it comes to e-discovery, dry topics are unavoidable. But you’ll just have to trust me for however many inches this column ends up being that the differences between the forms of production for e-discovery is important and worth knowing. That’s because the form of production affects both the usefulness of what is produced and the cost of producing it.
Generally, there are three types of forms that a party can use when producing electronic discovery: native, image and paper. The main distinction between the three forms of production is what metadata—i.e., the data about the data—is going to be produced. In broad strokes, paper comes with no (or virtually no) metadata, images come with only the metadata that is specifically harvested and packaged with the production, and native productions come with all the metadata. But this just raises the question, why does metadata matter?
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