In Kravetz v. Paul Revere Life Ins. Co., et. al., 2009 U.S. Dist. LEXIS 51230 (D. Az. June 11, 2009), U.S. Magistrate Judge Frederick J. Martone granted defendants' motion to compel production of computer hard drives and computer storage media, but limited defendants' review of the devices to certain metadata fields.

Plaintiff filed this disability action.  Defendant's moved to compel production of plaintiff's hard drives from his home and business to determine the number of hours plaintiff spent typing on a typical day which was relevant to his disability claim.  Plaintiff's e-discovery expert contended that defendants would not be unable to discern the number of hours spend from analyzing the hard drives.  Plaintiff's further asserted that defendants' request was overly broad and unduly burden-some.

The court held that defendants could ascertain plaintiff's computer work habits by reviewing the metadata from plaintiff's hard drives and media devices.  However, the court ruled that defendants did not need to see, and were prohibited from viewing, the substance of the documents themselves.  Therefore, the court ordered plaintiffs to provide the requested computer hard drives and devices with the limitation that defendants' could only extract metadata.