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In Bakhtiari v. Al-Khadedy, et. al. [pdf], No. 4:11-CV-971 (E.D. Missouri Dec. 30, 2011), U.S. District Court Judge Stephen N. Limbaugh, Jr. granted the defendants’ motion for a preservation order and limited discovery to examine the plaintiff’s electronically stored information. The court held the order was necessary given allegations related to the plaintiff’s prior destruction of emails.