Florida Circuit Court Judge Elizabeth Maass had entered summary judgment in favor of Ronald Perelman in his fraud case against Morgan Stanley as a sanction for refusing to turn over documents, including large numbers of e-mails.

See Gasparino, “Time to Invest in Some More E-Storage Space” Newsweek, May 30, 2005, p.12; “All That Missing E-Mail … It’s Baaack” New York Times, May 8, 2005.