The California Court of Appeal held that under federal law a nonparty cannot avoid complying with a subpoena seeking electronically stored information on the ground that it must create new code to format and extract that information from its existing systems. After identifying subpoenaed parties’ obligations to extract existing data from computer systems the court upheld an award of attorneys’ fees against the third party.
More information on Vasquez v. California School of Culinary Arts, Inc. (Sallie Mae) (2014) 230 CA4th 35 are available at http://www.technethics…
For more information contact Nathan M. Crystal
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