responsive
Under Rule 34, production that is not ‘naturally organized’ must be labeled
The court granted a motion to compel, finding that disorganized ESI did not satisfy FRCP 34; it ordered amendment of all non-conforming productions.
Court ‘not convinced’ that review would be disproportionate
In this trademark infringement case, the court ordered the defendants to review a random sample of documents using a code name for responsiveness.