Chapter 3 - FORM 3-1 : LETTER TO CO-DEFENDANT'S COUNSEL—PRESERVATION OF DOCUMENTS

• Jurisdiction: Colorado

Form 3-1: Letter to Co-Defendant's Counsel—Preservation of Documents

[date]

VIA FACSIMILE AND REGULAR MAIL

[name and address of co-defendant's counsel]

Re: [lawsuit identification information]

Dear [name of co-defendant's counsel]:

[Name of client] understands that your firm has been retained to represent [name of co-defendant] in the above-designated lawsuit. As you know, [name of client] has also been named as a defendant in the lawsuit. Because it is possible that current employees of [name of co-defendant] may have in their possession documents and/or electronic data that may be considered relevant to the allegations made by [name of plaintiff] of [allegations or claims], we are writing to request that a litigation hold be placed on the destruction of any such documents and/or electronic data by [name of co-defendant] pending the final resolution of this litigation.

[Name of client] is therefore requesting that [name of co-defendant] and its employees preserve all data and documents relating to [subject matter of lawsuit]. Documents and data would...