A spoliation letter, also known as a preservation letter or demand to preserve evidence, is a formal legal notice sent by one party (usually through their attorney) to a potential or opposing party in litigation.

Its core purpose is to formally notify the recipient of their legal duty to preserve specific, relevant evidence (physical objects, documents, electronic data, etc.) that could be material to a potential or pending legal claim.

By sending the letter, the sender establishes clear notice, making it much easier to request court sanctions or an "adverse inference" against the recipient if they subsequently destroy or alter the evidence, an act known as spoliation of evidence.

Herein is the complete text of a spoliation letter - demand to preserve evidence sent to Anthony R. Friedman to his mailing address at 6209 Mid Rivers Mall Dr. Ste. 204 St. Charles, Mo. 63304 via. registered mail, return receipt on Oct. 16, 2025

Date: October 16, 2025

Delivered via: Email on October 15, 2025, and certified mail on October 16, 2025

From:
Albert B. Pepper Jr.
3420 Hanover Rd.
Columbia, IL 62236

To:
Anthony R. Friedman, d.b.a. The Friedman Law Firm LLC
6209 Mid Rivers Mall Dr. Ste. 204
St. Charles, MO 63304

Dear Mr. Friedman,

This letter serves to advise you, Anthony R. Friedman, d.b.a. The Friedman Law Firm LLC, that I, Albert B. Pepper Jr., currently acting pro se, demand the preservation of any and all evidence pertinent to the attorney-client relationship established via contract between myself and you, as well as The Simon Law Firm, P.C., with regard to representation in the complaint and petition of Pepper v. Gelfand, Chesterfield MedCenter, et al., and CVS Pharmacy, Case No. 19SL-CC04680, in the 21st Judicial Circuit, St. Louis County, Missouri.

Please be advised that you will be named as a defendant, jointly and severally, in a legal malpractice complaint regarding the representation provided to me in the aforementioned case. The filing of this complaint is imminent.

Therefore, I demand that you preserve and not alter any evidence related to the above matter, including, but not limited to, the following:

All hard copies and paper documents, including those with margin notes, commentary, addenda, post-it notes, attachments, or other tangible items, generated by you or provided to you by a third party during your tenure at The Simon Law Firm, P.C. and thereafter.

All electronic documents and correspondence, including those retained on computers, hard drives, servers, cloud storage, cell phones, laptops, thumb drives, zip drives, emails, text messages, audio recordings, or video recordings, that pertain directly or indirectly to me or the matter of Pepper v. Gelfand.

All video or audio recordings and minutes from telephone conversations, Skype or other internet communications, or meetings conducted at The Simon Law Firm, P.C. or elsewhere, that feature or reference, directly or indirectly, me or the matter of Pepper v. Gelfand.

All third-party documents, correspondence, or evidence obtained by, through, or shared with a third party, whether by contract or casual acquisition, including, but not limited to, communications with opposing counsel, expert witnesses of opposing counsel, mediators, the indemnifier of the defendant in Pepper v. Gelfand, the defendant or their associates, and counsel or colleagues (retained or not) involved in the matter.

Any and all items, no matter how minor, such as notes or memoranda, that may pertain to me or the matter of Pepper v. Gelfand. These must be retained and made available to me or my counsel (yet to be named) upon a formal discovery request, in accordance with the Missouri Rules of Civil Procedure.

Any and all items post withdrawal of representation and departure from the Simon Law Firm P.C. including but not limited to correspondences and communications with your former employer the Simon Law Firm P.C., Saint Louis Metropolitan Police Department (with regard to harassment complaint), Saint Charles County Police Department (with regard to harassment complaint), JouwWeb B.V. d.b.a. Webador (with regard to complaint for content on the website www.notthefriedmanlawfirmllc.com), third parties wherein there is not the attorney client privilege. 

Furthermore, per the contractual agreements dated January 1, 2019, and February 15, 2019, between myself and The Simon Law Firm, P.C., you were obligated to retain all case file documents, including hard copies and tangible items, for no less than ninety days after the conclusion of the case or your withdrawal from representation. As you departed The Simon Law Firm, P.C. in June 2023, I demand that any such items still in your possession or control be retained without regard to the ninety-day period. If you claim that any items are no longer in your custody and have been disposed of, either deliberately or inadvertently, I will require details regarding the date, method, responsible party, and certification of said destruction.

Be advised that you were made aware of potential litigation through prior phone conversations, email correspondence, and my social media activity. Upon receiving such notice, it was incumbent upon you to preserve all evidence, including, but not limited to, case files, hard copies, paper documents, and tangible items.

Please confirm receipt of this letter and your intent to comply with this preservation demand. Failure to preserve the requested evidence may result in sanctions under Missouri law.

Sincerely,

Albert B. Pepper Jr.
Litigant Pro Se

3420 Hanover Rd.
Columbia, IL 62236
Phone: 314-580-1684
Email: litigant.pro.se.advocate@gmail.com

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