ESI export de-identification is the removal of personal data from electronically stored information (ESI) before the Rule 26(f) conference. FRCP 26(f)(3)(C) makes the parties state their views on the form of production. anonym.plus does the pass on your own device.
When this applies
FRCP 26(f)(3)(D) asks the parties to raise privilege issues early, including whether to seek an FRE 502(d) order. Scoping a bulk export before that order exists leaves a vendor holding unreviewed privileged material.
How anonym.plus handles it
- Point anonym.plus at the export folder on your server.
- It scans both ID columns and free-text fields.
- Steady labels keep links across joined rows intact.
- Review the summary and tune the column rules.
- Replace or mask the confirmed PII.
- Save the clean dataset on your device for review.
What you need to provide
- The export as CSV, JSON, or a bundle of files.
- A column map for known ID fields.
- Replace with a steady label map to keep table joins.
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | custodian field → [PERSON_n] |
| Identifiers | US_SSN | ssn column → [SSN] |
| Dates | DATE_TIME | sent_date → [DATE] |
| Contact | EMAIL_ADDRESS | from_email → [EMAIL] |
| Location | LOCATION | address fields → [ADDRESS] |
| Free text | PERSON / LOCATION | inline names → labels |
Compliance achieved
- Scopes an export for the FRCP 26(f)(3)(C) talk on production form.
- Steady labels hold custodian joins, so volume counts stay defensible.
- No upload, so no vendor sees data before an FRE 502(d) order lands.
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Limitations & cautions
Bulk data mixes tidy columns with messy free text. Column rules handle the first well. Free-text fields need the same review as any note. Test a sample before a full run, and confirm joins still hold after the swap.
Frequently asked questions
What does Rule 26(f) actually require about ESI?
The discovery plan must state the parties' views on disclosure of electronically stored information, including the form or forms of production, under Rule 26(f)(3)(C). Rule 26(f)(3)(D) covers privilege issues and a possible FRE 502(d) order.
Why de-identify before the conference?
Scoping needs counts and custodian coverage, not identities. A cleared export lets you share volume figures with the other side, or with a consultant, exposing nobody.
Can records stay linkable after the swap?
Yes. A steady label map swaps each ID the same way, so rows for one custodian still join while no real identity is left.
Does it handle both CSV and document exports?
Yes. Tidy CSV or JSON columns and bundled files are both supported.