Following Magistrate Judge Paul S. Grewal's grating of an Apple motion for an adverse inference jury instruction against Samsung for continued deletion of emails even when the pre-trial process began, Samsung has filed for one of its own. A previous ruling opened the door for Samsung's filing, saying in a footnote that Apple's alleged failure to issue formal litigation hold notices to its employees on some communications in August 2010 allowed Samsung to argue (at the appropriate time) that Apple is also guilty of evidence spoliation. Apple has filed a motion to strike, due to Samsung's "untim
