In National Day Laborer Organizing Network v. U.S. Immigration and Customs Enforcement Agency , U.S. District Judge for the Southern District of New York Shira A. Scheindlin, author of the highly-influential Zubulake and Pension Committees opinions and one of the most respected jurists writing about e-discovery matters, held that not only must metadata be produced when e-files are being produced in discovery, but that such data must be produced in a "load file" to make accessing the produced data easier for the requesting side.
What is striking about the opinion is what it does not say, but assumes, about e-discovery production — i.e., that metadata and, possibly, text will be extracted and formatted for use within a review database or platform.
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