In Venture Corp. v. Barrett, No. 13-cv-3384 (N.D. Cal. Oct. 16, 2014), the district court addressed a party’s obligation to organize its electronic document production pursuant to Fed. R. Civ. P. 34(b)(2)(E).  The plaintiff produced its documents in what the court characterized as a “document dump” of un-indexed PDF documents on a flash drive.  The plaintiff argued that it was required to do nothing further because the parties had agreed upon a format for production pursuant to Rule 34(b)(2)(E)(ii).  The defendant argued that the plaintiff was required to “organize[] and label[]” the documents to correspond to particular document requests, pursuant to Rule 34(b)(2)(E)(i).  The court reviewed Rule 34 and held that both parties’ positions were incorrect.  As the court explained, applying both sub-provisions of Rule 34(b)(2)(E) requires a producing party to:  “(1) either organize and label each document it has produced or…provide custodial and other organizational information [metadata]…and (2) produce load files for its production containing searchable text and metadata.”