Aguilar v. Immigration and Customs Enforcement Division of United States Department of Homeland Security
United States District Court for the Southern District of New York
255 F.R.D. 350 (2008)
- Written by Rich Walter, JD
Facts
Adriana Aguilar (plaintiff) sued the federal Immigration and Customs Enforcement Division of the United States Department of Homeland Security (ICE) (defendant) for civil-rights violations. Aguilar’s initial discovery request asked ICE to produce electronically stored information (ESI) from ICE’s Excel software. The parties could have met and conferred to clarify Aguilar’s expectations as to the format in which ICE would produce this ESI, but they failed to do so. As a result, Aguilar’s interest in ICE’s Excel metadata did not become clear until after ICE produced Excel spreadsheets that had been stripped of that metadata. Had ICE used Excel to take advantage of that program’s computational capabilities, the metadata would have been relevant to show how ICE populated its Excel spreadsheets. However, ICE used Excel primarily to display, in a tabular format, content that easily could have been produced on a word processor. Thus, the metadata was unlikely to reveal anything that Aguilar could not learn from the scrubbed spreadsheets themselves. Nevertheless, Aguilar filed a follow-up discovery request demanding production of the metadata. ICE objected that the metadata was irrelevant but admitted that it could produce the metadata without undue burden. Aguilar petitioned the federal district court to compel production of the metadata.
Rule of Law
Issue
Holding and Reasoning (Maas, J.)
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