First American Title Insurance Company v. Northwest Title Insurance Agency, LLC, No. 2:15-cv-00229-DN-PMW (D. Utah, Aug. 31, 2016).

Key Insight: no spoliation becuase no evidence responsive data deleted and no prejudice. Oral litigation hold upheld, but be wary.

Nature of Case: Breach of Contract; Unfair Competition

Electronic Data Involved: Various ESI- personal emails, files from work computer

Keywords: oral litigation hold; spoliation