In Scott v. Moniz, No. 14-CV-5684-RJB (W.D. Wash. June 19, 2015), the district court held that a defendant “failed in its duty to preserve evidence” when it did not implement a document hold at the time the plaintiff filed an administrative claim for discrimination.  The court held, however, that it would be “premature to issue the requested sanctions” because discovery was ongoing and the court would not have a complete “picture of the prejudice” to the plaintiff until the completion of “additional discovery and depositions.”  The court continued the motion for sanctions until “discovery is complete,” at which time “Plaintiff can make further showing of prejudice, if any.”