In Peterson v. Matlock, No. 11-2594 (D.N.J. Oct. 29, 2014), the court denied plaintiff’s motion to compel prison officials to produce electronic medical records in native format from a specialized computer system. The court held that, under Rule 34, documents must be produced in native format if so requested unless the producing party can demonstrate “undue hardship or expense.” The defendant established such a hardship by showing that it could not produce records in native format from the records system without “an inordinate drain of time and manpower” because of limitations in the computer system. The court acknowledged that a non-native “PDF record provided may be less convenient for Plaintiff,” but requiring a native production would impose a “substantial hardship and/or expense, which outweighs Plaintiff's interests in receiving the records in their native format.” The court nonetheless ordered the defendant to produce certain “audit trail metadata” that the plaintiff had requested.