California, United States of America
The following excerpt is from Daus v. Howser, C082786 (Cal. App. 2018):
Further, by statute, "A party need not produce the same electronically stored information in more than one form." (Code Civ. Proc., 2031.280, subd. (d)(2).) The trial court ruled that Daus had already received the information in one format, citing this very statute. The court did not abuse its discretion by following the statute, and declining to find that an exception to the "one form" default for electronically stored information was needed in this case. That was a question falling well within the discretion Daus concedes a trial court possesses in ruling on a discovery motion. (See, e.g., Krinsky v. Doe 6 (2008) 159 Cal.App.4th 1154, 1161.)
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