In re Atl. Marine Prop. Holding Co., Inc., 2009 WL 1211399 (S.D. Ala. Apr. 29, 2009)

Key Insight: Where court ordered company to obtain waivers from employees allowing their personal email providers to release certain communications for production but where the email providers indicated their inability to provide those communications, court declined to order adverse inference where there was no evidence to indicate company acted in bad faith or purposefully lost or destroyed the emails

Electronic Data Involved: Email from employees’ personal accounts