“District Judge Barbara Crabb held that the Defendants could not produce what they did not have in their possession. Carter, at *7. Judge Crabb went on to order something that should be standard: identify the steps taken to determine whether there are any responsive documents. Carter, at *7-8. Merely stating “no emails found” was not enough.”
Umm yeah, You’re gonna need to come up something more than “nope, nothing to see here” in response to an ediscovery request. If there truly isn’t anything to see here, you’re gonna need to show how you came to that conclusion. Search hit reports anyone?