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On to compel, Jannx Medical Systems, Inc. v. The Methodist Hospitals, Inc., 2010 WL 4789275, U.S. Magistrate Judge Paul R. Cherry found a plaintiff s production of electronic documents in PDF format without searchable text did not comply with Federal Rule of Civil Procedure 34 (Rule 34). As highlighted by this opinion, parties cannot rely on the absence of an agreement regarding form of production, or lack of specified form of production in discovery requests, as a basis for producing document.

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