Chapter 1 - FORM 1-23 : PLAINTIFF'S INTRACOMPANY MEMORANDUM REGARDING PRESERVATION OF EVIDENCE

• Jurisdiction: Colorado

Form 1-23: Plaintiff's Intracompany Memorandum Regarding Preservation of Evidence

MEMORANDUM

TO: __________
FROM: __________
DATE: __________

RE: Retention of Documents Relevant to Allegations of [lawsuit]

VERY IMPORTANT REMINDER

As most of you know already, we are considering filing (or have filed) a lawsuit against [name of defendant] relating to [subject of the lawsuit].

We have an obligation to preserve all documents potentially relevant to the lawsuit. Accordingly, it is extremely important that documents or information relating to [subject of the lawsuit] NOT be destroyed. This is true for all documents and information relating to the lawsuit, whether created before or after you receive this memorandum. Our company could face serious adverse consequences if any of these documents or information are destroyed, even if done unintentionally. Therefore, please retain all such documents or information, including e-mail correspondence and voice-mail messages, either as hard copies or electronically in your computer until further notice. Please also instruct all personnel...