Smyth v. Merchants Credit Corp., No. C 11-1879RSL, 2013 WL 5200811 (W.D. Wash. Sept. 16, 2013)

Key Insight: Court declined to compel re-production of data in native format where no form of production was requested and where the producing non-party had already produced responsive information in hard copy

Nature of Case: debt collection

Electronic Data Involved: ESI