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A federal district court in New Jersey has ruled, in Haskins v. First American Title Ins. Co., No. 10–5044 (RMB/JS) (D.N.J. Oct. 18, 2012), that a title insurer that is a defendant in a civil suit was in “possession, custody, or control” of documents held by its “independent title agents” and therefore was under a duty to direct its agents to “preserve” the documents. 

The Case 

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