Chapter 3 - FORM 3-3 : DEFENDANT'S INTRACOMPANY MEMORANDUM—RETENTION OF DOCUMENTS RELEVANT TO LAWSUIT

• Jurisdiction: Colorado

Form 3-3: Defendant's Intracompany Memorandum—Retention of Documents Relevant to Lawsuit

MEMORANDUM

TO:

FROM:

DATE:

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

VERY IMPORTANT REMINDER

As most of you know already, a lawsuit has been filed against the Company relating to [subject matter of lawsuit]. We intend to fight these allegations vigorously.

We have an obligation to preserve potentially relevant documents. Accordingly, I remind you that it is extremely important that documents or information prepared from [date] to the present concerning the following [insert details] may NOT be destroyed. The 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, whether in hard copy or on your computer equipment, including e-mail correspondence and voice-mail messages, until further notice. Please also instruct all personnel that you supervise...