No Sanctions for Spoliation? | eLessons Learned
In a decision handed down in October 2013, the court in P.R. Telephone Co.
v. San Juan Cable, LLC. held that, under certain circumstances, a company
may have a duty to preserve emails from personal email accounts of current
and former employees. In P.R. Telephone, the Puerto Rico Telephone Company
(PRTC) alleged that OneLink Communications failed to preserve emails
relevant to the case from the personal email accounts of former employees.
Thus, PRTC brought a motion for sanctions due to spoliation of evidence.

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Source: http://ellblog.com/no-sanctions-for-spoliation/
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