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Requesting Spreadsheets in Discovery: Quinonez-Castellanos v. Performance Contractors, Inc.

by Joshua Gilliland

The key discovery in a case is usually a limited number of documents, sometimes just one specific record. The goal of document review is to efficiently find responsive data in a time effective manner. Spreadsheets are often key evidence in a case and can prove crucial information about anything from transfer of money, to safety data about medications, to scheduling of individuals. The ability to quickly search spreadsheets can greatly improve document review efficiency.

A Formula for Proportionality

Earlier this year, in a civil rights case involving retaliation and sexual discrimination, Chief Magistrate Judge C.J. Williams, for the Northern District of Iowa, applied formulas of relevance and proportionality in ordering the production of a single Excel file. 

The case of Quinonez-Castellanos involved the scope of discovery focusing on a single employee who allegedly harbored discriminatory or retaliatory animus at multiple construction sites, resulting in the scope of discovery including the locations where that individual worked. (See Quinonez-Castellanos v. Performance Contractors, Inc., No. 16-cv-4097-LTS, 2017 U.S. Dist. LEXIS 126018, at *16-19 (N.D. Iowa Aug. 9, 2017)). One issue in the discovery dispute was over an Excel file and related emails in two separate discovery requests.

A deponent testified in deposition that the Excel file contained information regarding employee complaints from 2012 to present. The related emails were messages regarding complaints about a specific person that were recorded in the Excel file.

The Court held that the Plaintiff made a showing of relevance about the spreadsheet, because the file was alleged to have information regarding employee complaints, which would show a pattern, or the lack thereof, of discrimination or retaliation.

The Court rejected the Defendant’s burdensome argument about the Excel file, as the spreadsheet contained only a limited number of complaints. The Court also ruled that the argument that the spreadsheet was not regularly maintained and thus should not be produced was “wholly devoid of merit.” As such, the Defendants had to produce the Excel file in native file format with metadata and the related emails.

Reviewing Excel Files in Everlaw

Many attorneys have stories about the challenges of reviewing information in spreadsheets. In cases like the above, one Excel file was a highly relevant document that needed to be reviewed. This historically has required attorneys to spend substantial time analyzing cells within a spreadsheet for their content.

Attorneys can review searchable static spreadsheets in Everlaw. Reviewers can also search within spreadsheets and view cell information, hidden cells, cell notes, and graphs. Cell content can be viewed by clicking on a cell. Reviewers can navigate within a spreadsheet with the arrow keys, viewing the contents of each cell they select.

An attorney reviewing an Excel file like the one in the above case could first search within the entire spreadsheet for keywords such as “complaint” or the name of the individual who engaged in the alleged wrongful conduct. The total number of hits will be displayed. The reviewer can navigate to each of the different hits by either pressing “enter” on their keyboard or clicking the search button.  Notes can be added on any mental impressions of the spreadsheet. The document can also be coded according to how it relates to the causes of action in the case.

Email messages that are a “parent” to the Excel file could be identified in the results table by selecting the “Attachments” under Group. This will show parent emails which can be reviewed for their utility in proving claims or defenses.  

Sorting to Relevance

Document review is about finding relevant information. The power to search within a spreadsheet empowers attorneys to pivot from manual review of a spreadsheet to efficiently searching for specific formulas to prove the merits of a claim or defense. This allows attorneys to focus on preparing arguments based on facts, because they can find the supporting evidence with greater proficiency.