In the case Ford Motor Company, et al. v. Edgewood Properties Inc., Edgewood raised issues regarding Ford's production of documents, particularly concerning the format in which the documents were produced and the timeliness of Edgewood's objections. According to Principle 12 of the Sedona Principles, absent an agreement or court order, documents should be produced in their original form or a reasonably usable format, including necessary metadata. However, Edgewood's objection to the TIFF format used by Ford came after Ford had completed its rolling document production, which spanned from March to November 2008. The court found Edgewood's delay in objecting—waiting until after production was nearly complete—unreasonable and denied their request to reformat the documents, as it would impose an undue burden on Ford.

Edgewood also challenged the adequacy of Ford's document collection process, suspecting that critical documents might be missing. They requested permission to conduct a limited keyword search of Ford's electronically stored information (ESI) to confirm the thoroughness of the collection. However, the court upheld Ford's discretion in choosing the document collection method, noting that Edgewood failed to provide sufficient evidence of intentional or negligent withholding of documents. The court denied Edgewood's motion, suggesting they could revisit the issue if additional relevant documents emerged during depositions.

Additionally, Edgewood sought the production of a joint defense agreement between Ford and other parties, arguing that it might reveal biases or lead to discoverable evidence. After an in-camera review, the court determined that the agreement contained only standard, boilerplate language and was not relevant to the case. While the court denied the request to produce the agreement itself, it ordered Ford to disclose the parties involved, allowing Edgewood to explore potential biases through other discovery methods, such as depositions. Ultimately, the court emphasized the importance of timely objections and cooperation in the discovery process, as well as the need for parties to agree on document production methods early on to avoid disputes.

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