Representing the defendant, Zena, compose a legal memorandum for the supervising attorney, Miryam, addressing the following: Zena wants Yannick to produce some ESI documents, with their respective metadata, for an ongoing civil litigation case. Yannick thinks that he can delete certain data within these documents before submitting them to Zena. Yannick believes that the data he wants to delete is protected both ethically and legally so he ought not be compelled to submit that data to Zena.

As part of your preparation to write the internal legal memorandum:

-Review In re State Farm Lloyd, 520 SW3d 595 (Tex. 2017).

-Summarize the State Farm Lloyds case, including how its holding and reasoning could affect Yannick and Zena's situation, if at all. Be sure to define ESI and metadata and address the relevant civil procedure rules. Compare and contrast State Farm Lloyds to the current similar law within Indiana.