The best approach to understanding what is a document is to examine what information is readily available to the computer user in the ordinary course of business. If the employee can view the information, it should be treated as the equivalent of a paper

The best approach to understanding what is a document is to examine what information is readily available to the computer user in the ordinary course of business. If the employee can view the information, it should be treated as the equivalent of a paper 'document.' Data that can be readily compiled into information, whether presented on the screen or printed on paper, is also a 'document' under Rule 34. [Note: Fed. R. Civ. P.] However, data used by a computer system but hidden and never revealed to the user in the ordinary course of business should not be presumptively treated as a 'document.' Nor should data that is not accessible except through forensic means, such as deleted or residual data.