Court Does Not Find E-mail Envelope Bereft of Substance Subject to Preservation Duty
Holt v. Northwestern Mut. Life Ins. Co., 2005 WL 3262420 (W.D. Mich. Nov. 30, 2005)
Dr. Steven Holt (“Holt”) purchased several disability insurance policies from Northwestern Mutual Life Insurance Company (“Northwestern”) while working as an emergency room physician. He made a claim for payment, which was denied, and thus filed suit. In a motion to compel discovery and award sanctions, Holt asserted that Northwestern had committed discovery violations including the spoliation of email. Read More