Motion to Compel Response in Native Format With Metadata

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

________________________________

) Case [Form] No.: 7.1(e)

Peter Plaintiff, )

Plaintiff, )

)

v. )

)

Donald Defendant, )

Defendant )

________________________________ )

Moving Party: _____________

Respondent: _____________

MOTION TO COMPEL RESPONDING PARTY

TO PRODUCE ELECTRONIC DOCUMENTS

IN A NATIVE FORMAT WITH METADATA INCLUDED

The Moving Party, ______________, by and through his attorneys, hereby requests that this honorable court issue its order requiring the Respondent to produce those documents requested pursuant to the Notice For Production of Documents previously submitted to the Respondent on _______, 20 __, and further that this court, by its order require that such requested documents be produced in a native form with all metadata included. The basis for this motion is as follows:

1. The Moving Party did, in conjunction with the applicable court rules, submit a Notice For Production to the Defendant on _______, 20__ requesting the production of various __________ at the offices of _________________ located at _______________________.

2. The items requested in the Notice For Production of Documents, which are all relevant, material, and necessary for the preparation of the Moving Party’s case, consist of the following:

   _________________________________________________________________________

   _________________________________________________________________________

   _________________________________________________________________________

   _________________________________________________________________________

   _________________________________________________________________________

   __...