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Alex considers Zakre v. Norddeutsche Landesbank Girozentrale (2004 WL 764895) where the The Southern District of New York determined that it was OK for the producing side to turn over 200,000 emails and attachments which had been "converted to plain text with an ASCII extraction utility and delivered in standard, non-delimited format to the requesting party" ... or as Alex puts it, "one step above a pure paper production in the sub-par chart."

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