KnifeSource, LLC v. Wachovia Bank, N.A., 2007 WL 2326892 (D.S.C. Aug. 10, 2007)

Key Insight: Where defendant stated it did not maintain physical copies of statements and that compliance with production request would impermissibly require it to create documents, court found that defendant had not shown requested information was “not reasonably accessible” and ordered production to the extent defendant maintained any of the requested information electronically

Nature of Case: Conversion

Electronic Data Involved: Customer account statements