Shareholder disputes in closely held Michigan businesses often begin with familiar accusations. A minority owner believes money is being diverted, distributions have stopped without explanation, controlling shareholders are paying themselves excessive compensation, corporate assets are being transferred, or the value of the company is being deliberately concealed. The majority owners may respond that the company is struggling, the challenged expenditures were legitimate business decisions, or the minority shareholder simply does not understand the company’s finances. In many cases, however, the dispute eventually turns on a more basic question: where are the financial records?
Please note this blog post should be used for learning and illustrative purposes. It is not a substitute for consultation with an attorney with expertise in this area. If you have questions about a specific legal issue, we always recommend that you consult an attorney to discuss the particulars of your case.
That question can determine far more than whether one side has complied with discovery. Corporate books, accounting records, bank statements, tax returns, general ledgers, shareholder records, valuations, and related financial information often form the evidentiary foundation for claims involving shareholder oppression, breach of fiduciary duty, distributions, excessive compensation, misuse of corporate assets, and the value of an ownership interest. When those records are incomplete, withheld, lost, or destroyed, the absence of evidence may affect liability, damages, valuation, available remedies, and even which claims can reach a factfinder.
The Michigan Court of Appeals’ 2026 published decision in Turner v J & J Slavik, Inc. provides a particularly important illustration. ¹ Turner involved decades of litigation concerning a shareholder’s ownership interest, his efforts to obtain corporate financial information, and the value of his shares. The missing records ultimately produced an unusual result. Their absence helped defeat one claim because damages could not be established without speculation, while the circumstances surrounding their destruction supported an equitable remedy on a separate shareholder-oppression claim. Turner therefore offers an important lesson for shareholders, directors, business owners, accountants, and attorneys throughout Michigan: missing records do not merely create a discovery problem. They can change the legal architecture of the entire case.
The starting point is the Michigan Business Corporation Act. Michigan law expressly requires a corporation to keep books and records of account, together with minutes of proceedings involving shareholders, the board of directors, and any executive committee. ² The statute also requires corporate records concerning shareholders, including ownership information. Although businesses have significant flexibility in how records are maintained, the statutory requirement reflects an important principle: corporate ownership and management are supposed to operate through records capable of documenting what the corporation owns, what it owes, who owns it, and how important corporate decisions were made.
That requirement becomes particularly significant in a closely held business. Unlike an investor in a large publicly traded company, the owner of a closely held Michigan corporation may have no public market price for the shares and comparatively little publicly available information concerning the company’s performance. The value of the minority shareholder’s investment may therefore depend heavily on financial information controlled by the corporation and its managers.
A shareholder who suspects that the corporation’s finances are being manipulated may need records showing revenue, expenses, cash flow, debt, compensation, distributions, shareholder loans, related-party transactions, accounts receivable, accounts payable, inventory, real estate, equipment, tax liabilities, and other assets and obligations. Without reliable records, determining whether a corporation is profitable, insolvent, transferring value to insiders, or withholding distributions for legitimate business reasons can become extraordinarily difficult.
That information can become even more important when ownership itself must be valued. A valuation expert cannot simply announce what a private company is worth. The expert ordinarily needs reliable financial data from which to analyze earnings, assets, liabilities, historical performance, cash flow, and other relevant factors. If the underlying records disappear, the problem is not merely that discovery becomes inconvenient. The evidentiary foundation for the valuation may disappear with them.
Michigan law does not leave shareholders entirely dependent on the willingness of management to disclose information. MCL 450.1487 establishes statutory rights to financial information and inspection of corporate books and records. ³ Among other things, a shareholder may make a written request for the corporation’s balance sheet and income statement for the preceding fiscal year and, if prepared by the corporation, its statement of sources and application of funds.
The statute also permits a shareholder of record to inspect corporate books and records for a proper purpose. The demand must describe the purpose and requested records with reasonable particularity, and the records must be directly connected with that purpose. A “proper purpose” is one reasonably related to the person’s interest as a shareholder.
Those requirements matter. An inspection demand should not necessarily be treated as an informal request for every document associated with the business. A shareholder contemplating litigation should carefully identify the shareholder interest being investigated and connect the requested records to that purpose. A request seeking financial statements, general ledgers, shareholder distributions, officer compensation, related-party transactions, or records necessary to determine the value of an ownership interest may present a much different issue from an unlimited demand for every business document ever created.
When a compliant inspection request is refused or unreasonable conditions are imposed, MCL 450.1487 permits the shareholder to seek an order compelling inspection. The statute also contains a fee-shifting provision when a court orders inspection, subject to the corporation’s ability to establish the statutory good-faith justification for refusing access. ³ The procedural requirements therefore matter to both sides. A shareholder should create a clear record demonstrating compliance with the statute, while a corporation should not assume that ignoring or indefinitely delaying a proper request carries no consequence.
More fundamentally, access to corporate books itself is an important shareholder interest. The Michigan Supreme Court has recognized that the rights belonging to a shareholder include, among others, the rights to vote, inspect corporate books, and receive distributions.⁵ When those rights are substantially interfered with intentionally, the dispute may extend beyond document inspection and become part of a shareholder-oppression case.
Michigan’s shareholder-oppression statute, MCL 450.1489, permits a shareholder to bring an action when the directors or persons controlling the corporation engage in conduct that is illegal, fraudulent, or willfully unfair and oppressive to the corporation or shareholder.⁴ The statute defines willfully unfair and oppressive conduct in terms of a continuing course of conduct, significant action, or series of actions substantially interfering with the interests of the shareholder as a shareholder.
The Michigan Supreme Court’s decision in Madugula v Taub is significant because it explains that shareholder interests are not limited to the bare possession of a stock certificate. Those interests may arise from the Business Corporation Act, the corporation’s articles and bylaws, and enforceable shareholder agreements. The Court specifically recognized inspection of corporate books as one of the statutory rights associated with share ownership.⁵
The Court of Appeals has further explained that an oppression plaintiff alleging willfully unfair and oppressive conduct must establish not merely interference, but conduct meeting the statutory requirements, including the required intent to interfere with interests held as a shareholder. Franks v Franks emphasizes that the oppression statute does not impose automatic liability whenever shareholders disagree about corporate management.⁶ The nature of the conduct, the affected shareholder interest, and the controlling parties’ intent remain important.
Against that legal background, withholding financial information can become highly consequential. A refusal to disclose books may prevent a shareholder from understanding whether distributions are being improperly withheld. Missing payroll and compensation records may obscure whether controlling shareholders are withdrawing corporate profits through salaries or bonuses instead of distributions. Missing loan records may make it difficult to determine whether corporate funds were transferred to insiders. Missing asset records may prevent a minority shareholder from evaluating a proposed redemption or buyout.
A records dispute therefore may become part of the substantive oppression claim rather than merely collateral discovery litigation. Turner demonstrates how significant that distinction can become.
Turner v J & J Slavik, Inc., issued for publication by the Michigan Court of Appeals on June 12, 2026, arose from a shareholder’s attempt to obtain the value of his stock following termination from his position as the corporation’s chief executive officer .¹ The parties had entered into a stock restriction and redemption agreement requiring the shareholder to sell, and the corporation to purchase, his common shares at fair market value determined as of December 31, 1991.
The contemplated valuation did not occur. Litigation followed concerning whether the plaintiff remained a shareholder and what rights accompanied his ownership interest. Earlier appellate proceedings eventually established that the plaintiff’s shares had not been properly redeemed and that he remained a shareholder.
The dispute nevertheless continued. According to the Court of Appeals’ 2026 opinion, the corporation and its controlling shareholder continued refusing to provide information concerning corporate finances, operations, and shareholder meetings. The shareholder alleged that the refusal prevented him from determining the value of the corporation and his stock.
The eventual litigation included claims for breach of fiduciary duty and shareholder oppression. The trial court concluded after the bench-trial portion of the proceedings that the defendants had engaged in shareholder oppression through conduct that included refusing access to corporate books and records, failing to conduct the valuation contemplated by the redemption agreement, refusing to recognize the plaintiff’s continuing shareholder status, and manipulating or hiding corporate finances for the benefit of the controlling shareholder and family interests. ¹
The missing records became central to the result.
The trial court found extensive spoliation of the company’s financial and business records. As later described in the appellate opinion, the court regarded the conduct as a “massive and entirely successful campaign of spoliation” that had made it essentially impossible to value the company or the plaintiff’s stock through the historical financial evidence that ordinarily would have been available. ¹
That finding might initially appear to dictate a complete victory for the shareholder. It did not.
Instead, Turner demonstrates that the consequences of missing evidence depend on the legal claim and the remedy being sought.
The plaintiff asserted a breach-of-fiduciary-duty claim against the controlling shareholder. The trial court directed a verdict against the plaintiff on that claim, and the Court of Appeals affirmed. ¹
The reason is one of the most important lessons in Turner.
Even where wrongdoing has occurred, a plaintiff pursuing damages ordinarily must establish the damages caused by that wrongdoing with sufficient certainty. Michigan law does not require mathematical precision in every case, but damages cannot rest entirely on speculation or conjecture. In Turner, the financial evidence necessary to establish the corporation’s value during the relevant period was missing. The appellate court observed that there was a six-year evidentiary gap without competent financial proof from which the jury could reasonably determine the corporation’s value or the value of the shareholder’s interest. ¹
The plaintiff argued that the absence of evidence resulted from the defendants’ own spoliation. That fact was certainly significant, but it did not automatically supply the missing valuation evidence. Even assuming that an adverse inference could be drawn against the party responsible for the loss of evidence, an inference that the missing evidence would have been unfavorable was not the equivalent of reliable evidence establishing a particular dollar value.
That distinction is critical in business litigation. A court may conclude that missing financial records would have hurt the party responsible for their disappearance yet still determine that the remaining evidence is insufficient to calculate damages. An adverse inference might support the conclusion that the corporation was more valuable than claimed. It does not necessarily establish that the corporation was worth $2 million, $5 million, or $20 million.
This creates a danger for plaintiffs that can be overlooked when spoliation is discovered. Proving that an opponent destroyed favorable evidence does not necessarily eliminate the plaintiff’s burden to establish damages. If the claim requires a particular valuation and every reliable source of historical valuation data has disappeared, the destruction can paradoxically injure the plaintiff twice: first by depriving the plaintiff of evidence, and again by making damages too speculative to recover.
Turner therefore provides an important strategic lesson. Counsel confronting missing records should not focus exclusively on obtaining a spoliation finding. They should simultaneously investigate alternative evidentiary sources capable of reconstructing the company’s financial condition. Tax filings, bank records, lender files, accountant work papers, customer records, insurance submissions, property records, historical appraisals, financial statements delivered to third parties, and testimony from accountants or officers may sometimes provide independent evidence from which value can be reconstructed.
The absence of the corporation’s own accounting records may be damaging, but a case should not automatically depend on the assumption that an adverse inference will fill every evidentiary gap.
Turner becomes particularly significant because the result changed when the court moved from the fiduciary-duty claim seeking damages to the shareholder-oppression claim.
MCL 450.1489 gives a circuit court broad authority to fashion relief when shareholder oppression has been established. Available remedies include directing or prohibiting corporate actions and ordering the corporation or responsible shareholders, directors, or officers to purchase the oppressed shareholder’s shares at fair value.⁴
The Michigan Supreme Court explained in Madugula that an action under MCL 450.1489 is fundamentally equitable in nature.⁵ A forced purchase of shares under subsection (1)(e) remains an equitable remedy even though the ultimate result is the payment of money. That distinction gives the circuit court broader remedial flexibility than a jury deciding a conventional damages claim.
That flexibility became decisive in Turner.
The trial court concluded that the missing records made a conventional historical valuation practically impossible. But it also concluded that the defendants themselves were responsible for creating that impossibility. The court therefore used adverse inferences when considering the financial position of the corporation and exercised its equitable authority under MCL 450.1489 to fashion a remedy.
The court relied on the only uncontroverted evidence of stock value that remained: the $25,000 cash amount the plaintiff had originally paid for his shares. It then incorporated interest in establishing the fair-value remedy. The final judgment required the defendants to purchase the plaintiff’s shares for $25,000 plus simple interest calculated at seven percent per year from May 1992. The Court of Appeals affirmed the equitable treatment. ¹
The contrast is striking. The same absence of financial records that prevented a jury from calculating compensatory damages with reasonable certainty did not leave the court powerless under the oppression statute. Equity permitted the court to consider how the evidentiary void had been created and to fashion relief from the evidence that remained.
That does not mean that every shareholder faced with missing financial records will receive an estimated buyout or that a court is free to invent a valuation. Turner arose from extraordinary facts involving a lengthy history, a redemption agreement, repeated denials of shareholder rights, and findings concerning extensive spoliation. But the decision demonstrates why the selection and development of claims can have enormous consequences in closely held business litigation.
A plaintiff who treats an oppression claim merely as another form of damages claim may miss an important part of the statute. Conversely, a defendant who assumes that destroying the evidence needed to calculate damages necessarily prevents meaningful relief may seriously underestimate the equitable authority available to the circuit court.
Michigan law has long recognized circumstances in which missing evidence may support an adverse inference. In Ward v Consolidated Rail Corp, the Michigan Supreme Court explained that an adverse inference may be appropriate when material evidence was within a party’s control, could have been produced, was not equally available to the opposing party, and the party lacks a reasonable explanation for failing to produce it.⁷ The nature of the inference and the circumstances permitting it remain important; not every missing document establishes intentional destruction or wrongdoing.
Similarly, Komendat v Gifford recognizes that a failure to preserve material evidence may justify a spoliation instruction when the necessary requirements are satisfied.⁸ Current Michigan discovery rules also expressly address electronically stored information that should have been preserved in anticipation or conduct of litigation. MCR 2.313(D) authorizes measures designed to cure prejudice from lost ESI and permits more severe measures, including unfavorable presumptions, adverse instructions, dismissal, or default, when the required intent to deprive another party of the information is established. ¹⁰
Turner adds a business-litigation dimension to these principles. An adverse inference can influence the court’s assessment of disputed financial circumstances, but it is not necessarily a substitute for proof of a specific dollar amount. That distinction should shape discovery strategy from the beginning of a shareholder dispute.
For the shareholder, the objective should be to preserve both the argument concerning the significance of missing evidence and every available alternative source of the underlying financial information. For the corporation, the objective should be to demonstrate how records were maintained, what was preserved, what was lost, why it was lost, and whether equivalent information can be recovered elsewhere. A credible explanation based on ordinary record-management practices presents a materially different situation from selective destruction after a dispute has arisen.
Modern shareholder disputes increasingly involve electronic financial evidence rather than boxes of paper ledgers. QuickBooks files, accounting databases, payroll systems, cloud-based banking records, tax software, emails with outside accountants, spreadsheets, document-management platforms, and backup systems can all contain relevant evidence.
Michigan discovery rules expressly include electronically stored information within discoverable documents. MCR 2.310 permits requests for documents and ESI within the permissible scope of discovery and addresses the form in which ESI may be produced.⁹
For that reason, preserving only printed financial statements may be insufficient in a serious ownership dispute. The native accounting database can contain transaction histories, adjustment information, account classifications, and details that are absent from a year-end profit-and-loss statement. Emails may explain why transactions were characterized in a particular manner. Payroll records may establish changes in shareholder compensation. Bank data may reveal transfers not readily apparent from summaries created for litigation.
Once litigation is anticipated or underway, the loss of relevant electronic information can raise issues under Michigan’s specific ESI-preservation rule. ¹⁰ Consequently, businesses involved in emerging shareholder disputes should consider preservation before computers are replaced, accounting systems are migrated, cloud accounts are closed, backup schedules overwrite information, or former employees’ email accounts are deleted.
A preservation strategy should also identify who actually possesses financial information. In a closely held company, critical records may exist with the corporation’s outside accountant, bookkeeper, payroll company, bank, lender, insurance agent, or tax preparer rather than within the company’s physical office. This is important both for preservation and for reconstruction when the company itself claims records no longer exist.
Many shareholder disputes present competing narratives that cannot be resolved merely by examining corporate resolutions or listening to the shareholders’ testimony.
Suppose a profitable company historically made distributions but abruptly stops making them after a dispute with a minority shareholder. The majority may contend that cash must be retained because business conditions have deteriorated. The minority shareholder may claim profits are instead being redirected through increased salaries, management fees, shareholder loans, or related companies.
The financial records may decide which narrative is supported.
Likewise, the fact that a controlling shareholder receives a substantial salary does not by itself establish oppression. The relevant inquiry may require examination of historical compensation, duties performed, company profitability, comparable compensation, distributions, bonuses, and whether compensation changed after the shareholder dispute began.
The same is true when a company claims insolvency. A balance sheet, standing alone, may not resolve the issue if significant assets are carried at historical cost, liabilities are disputed, related-party transactions exist, or valuable assets have been moved elsewhere. Historical records and supporting documentation may be necessary to determine the company’s actual financial condition.
In these cases, missing records can alter the credibility of the entire litigation position. A party asserting that its decisions were financially necessary is in a stronger position when contemporaneous records document that necessity. The same assertion may receive much greater scrutiny if the records that should verify it have inexplicably disappeared.
Few issues are more dependent on financial documentation than the valuation of an interest in a privately held Michigan business.
Unlike publicly traded stock, closely held shares generally have no quoted market price. Valuation may therefore require detailed consideration of the company’s assets, liabilities, earnings history, expected cash flows, customer relationships, debt, capital requirements, and other financial characteristics.
The distinction between “fair value” under MCL 450.1489 and contractual concepts such as “fair market value” may also matter. Turner itself involved a redemption agreement referencing fair market value at a historical valuation date, while the oppression statute authorized the circuit court to order a purchase at fair value. ¹ The terminology and governing legal source should therefore be identified before an expert valuation is developed.
When years of financial data are unavailable, the problem can become severe. A valuation expert cannot reliably reconstruct historical earnings from memory. Nor can an expert simply assume that every uncertainty should be resolved against one party. Expert opinions still require evidentiary foundations.
Turner demonstrates the resulting tension. The destruction of evidence may support adverse consequences against the responsible party, but conventional damages may still fail if there is no reasonable method of determining the amount. In equity, however, the judge may have broader authority to determine an appropriate remedy from the evidence that remains.
The lesson for litigants is that valuation evidence should be addressed early. Waiting until the eve of expert discovery to determine whether historical accounting data exists can place the entire case at risk.
Shareholder litigation often involves sharply conflicting testimony from people who worked together for years. Each participant may have a different explanation for why distributions stopped, why salaries changed, why money was transferred, or why a shareholder was excluded from information.
Contemporaneous financial records can provide an objective reference point. Their absence can therefore affect more than valuation.
If a director testifies that a large payment was repayment of a shareholder loan, the existence of contemporaneous loan documentation may be important. If management claims distributions were suspended because of cash-flow concerns, board materials and financial statements from the relevant period may support or undermine that explanation. If a shareholder contends that assets disappeared, fixed-asset schedules, sale documents, and bank deposits may reveal what happened.
When those records should exist but cannot be located, litigation increasingly turns toward questions concerning record custody, retention practices, electronic systems, accountants, backups, and the circumstances under which information disappeared. What began as a dispute over corporate management can become a dispute over evidentiary credibility.
Turner illustrates the danger of allowing that process to continue for years. Once the original financial evidence is gone, even a later judicial finding of misconduct cannot recreate precisely what the records would have shown.
A shareholder who believes financial misconduct may be occurring should generally consider the condition of the documentary record early in the dispute. Waiting years before requesting records can create significant evidentiary problems even where the shareholder ultimately has a valid claim.
A carefully drafted statutory inspection demand may serve several purposes. It may obtain the information necessary to determine whether litigation is warranted. It may establish precisely what records were requested and when. It may reveal inconsistencies in the corporation’s explanation concerning which records exist. It can also create a record of refusal if management prevents the shareholder from exercising statutory inspection rights.
The demand itself should be tied to a legitimate shareholder purpose and identify records with sufficient particularity to satisfy MCL 450.1487.³ Where litigation follows, ordinary civil discovery under MCR 2.310 can expand the inquiry into relevant documents and ESI.⁹
Early action can also improve valuation. Historical bank statements, tax returns, accounting data, and third-party records are generally easier to obtain before account closures, personnel changes, software migrations, and ordinary retention practices make retrieval more difficult.
The lesson operates in both directions. When a corporation becomes involved in a serious shareholder dispute, management should resist the temptation to treat requests for financial records as merely hostile demands from a disgruntled owner.
First, Michigan law independently imposes corporate record-keeping requirements and recognizes qualified shareholder inspection rights. ² ³ Second, the disappearance of financial information may create consequences extending well beyond an inspection claim. Third, maintaining reliable records may ultimately protect the corporation by demonstrating that disputed transactions were legitimate.
Companies should therefore evaluate where responsive financial information resides and whether routine deletion or destruction processes may affect it. That inquiry may extend beyond accounting files to emails, cloud storage, payroll data, bank records, tax files, board materials, valuation documents, and communications with outside financial professionals.
A company also should avoid creating unexplained gaps in its financial history. Turner demonstrates why. Once a court concludes that the absence of records resulted from deliberate conduct intended to prevent valuation or obscure shareholder rights, the missing records themselves may become a central feature of the oppression analysis.
Turner is significant because it rejects two overly simple assumptions.
The first is that spoliation automatically solves a plaintiff’s evidentiary problems. It does not. A party may establish serious misconduct surrounding missing records and still lose a damages claim because there is no reasonable evidentiary basis for calculating the amount of damages.
The second is that destroying valuation evidence necessarily protects the party controlling the records. It does not. In an equitable shareholder-oppression case, the court may consider both the missing evidence and responsibility for its disappearance when fashioning an appropriate remedy.
That combination makes Turner especially useful for Michigan business litigators. The question is not merely whether documents were lost. The questions are what the records would have been needed to prove, which party controlled them, why they are unavailable, whether equivalent information exists elsewhere, what remedy is being sought, and whether the claim is legal or equitable in character.
The answers can determine whether missing financial records weaken a claim, strengthen another claim, justify an adverse inference, affect a valuation, support a discovery remedy, or influence a court’s exercise of equitable discretion.
Shareholder disputes in Detroit, Ann Arbor, Oakland County, Washtenaw County, and throughout Michigan frequently involve businesses in which ownership, management, and personal relationships overlap. Financial information may historically have been shared informally. Corporate formalities may have been observed inconsistently. Owners who once trusted one another may never have insisted upon regular financial reporting.
That informality becomes dangerous when the relationship deteriorates.
A controlling owner may believe that because he or she operates the company every day, another shareholder has no legitimate reason to examine the records. A minority shareholder may assume that merely owning stock creates an unlimited entitlement to every company document. Neither assumption accurately reflects Michigan law.
The Business Corporation Act provides both rights and conditions. Corporations have record-keeping obligations. Shareholders have important inspection rights, but statutory requirements govern those requests. Oppression claims can provide substantial remedies, but a plaintiff still must establish the statutory elements. And when damages are requested, the plaintiff must still provide a reasonable evidentiary basis for calculating them.
Turner demonstrates what can happen when these principles collide over decades of missing information.
Financial records are often the factual foundation of Michigan shareholder litigation. They document whether a company is profitable, whether distributions were justified, whether insiders received disproportionate benefits, whether assets were transferred, whether shareholder loans were legitimate, and what an ownership interest may actually be worth.
The absence of those records can therefore change the outcome of a case.
The Michigan Court of Appeals’ published decision in Turner v J & J Slavik, Inc. provides a powerful example. The destruction and absence of financial records contributed to the dismissal of a fiduciary-duty claim because the shareholder could not establish nonspeculative damages. Yet those same circumstances supported adverse inferences and informed the circuit court’s exercise of equitable authority in granting relief for shareholder oppression. ¹
For minority shareholders, the decision emphasizes the importance of requesting records early, preserving evidence, identifying alternative sources of financial information, and matching the requested remedy to the available proof. For majority shareholders, directors, and corporations, it demonstrates the risk of withholding financial information or failing to preserve records once ownership disputes develop.
Most importantly, Turner confirms that a corporate records dispute is rarely only about documents. In Michigan business litigation, the existence or disappearance of the financial record may determine what can be proven, what remedies remain available, and ultimately how the dispute is resolved.
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Sources:
1- Turner v J & J Slavik, Inc, Mich App NW3d (2026) (Docket No. 370564), published opinion issued June 12, 2026. https://law.justia.com/cases/michigan/court-of-appeals-published/2026/370564.html
2-MCL 450.1485, Michigan Business Corporation Act, corporate books, records, and minutes. https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-450-1485
3- MCL 450.1487, Michigan Business Corporation Act, shareholder financial-information and inspection rights. https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-450-1487
4- MCL 450.1489, Michigan Business Corporation Act, actions and remedies for illegal, fraudulent, or willfully unfair and oppressive conduct. https://codes.findlaw.com/mi/chapter-450-corporations/mi-comp-laws-450-1489/
5- Madugula v Taub, 496 Mich 685; 853 NW2d 75 (2014). https://law.justia.com/cases/michigan/supreme-court/2014/146289.html
6- Franks v Franks, 330 Mich App 69; 944 NW2d 388 (2019).
https://case-law.vlex.com/vid/franks-v-franks-no-886408600
7-Ward v Consolidated Rail Corp, 472 Mich 77; 693 NW2d 366 (2005). https://caselaw.findlaw.com/court/mi-supreme-court/1309949.html
8- Komendat v Gifford, 334 Mich App 138; 964 NW2d 75 (2020).
https://case-law.vlex.com/vid/komendat-v-gifford-no-901252206
9- MCR 2.310, Requests for Production of Documents and Electronically Stored Information. https://www.courts.michigan.gov/siteassets/rules-instructions-administrative-orders/michigan-court-rules/court-rules-book-ch-2-responsive-html5.zip/index.html#t=Court_Rules_Book_Ch_2%2FCourt_Rules_Chapter_2%2FCourt_Rules_Chapter_2.htm
10- MCR 2.313(D), Failure to Preserve Electronically Stored Information. https://www.courtrules.net/michigan/michigan-court-rules/rule-2-313
This publication is for general informational purposes and does not constitute legal advice. Reading it does not create an attorney-client relationship. You should consult counsel for advice on your specific circumstances