Summary judgment on spoliation claim denied despite failure to implement formal litigation hold
Electronic Discovery Blog: Ed Schmidt Pontiac-GMC Truck, Inc. v. Chrysler Motors Company, LLC, 2008 U.S. Dist. LEXIS 51829 (N.D. Ohio Jul. 7, 2008)
Plaintiff requestor had sent a format litigation hold notice to defendant producer in October, 2004 regarding requestor’s contract claim against producer, although producer had been aware of the possibility of litigation since September, 2003. [...]