Spoliation by Highlighting
From Manning v. State of Washington, 2008 U.S. Dist. LEXIS 28403 (W.D. Wash. April 8, 2008):
The Court finds no evidence of spoliation. What appears to be blocked out language on the "kite" where Manning declares a medical emergency on July 6, 2004, simply occurred after highlighting in pink then copying, resulting in a grayed out, less legible printing. (Mentzer Declaration p. 2.) Nevertheless, Manning had a clearly legible version that he obtained before he filed this case.
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