Exhibit 8

Case 5:23-cv-00032-RWS Document 59-10 Filed 12/08/23 Page 1 of 3 PageID #: 1058
 

JW | DALLAS 2323 Ross Avenue, Suite 600 • Dallas, Texas 75201 | www.jw.com | Member of GLOBALAWTM

March 10, 2022

Via Federal Express and Email

Shy David Anderson

c/o Lisa Duffee

4311 Oak Lawn Ave

Dallas, TX 75219

lisa@d-elaw.com

Re: Document Preservation Notice

Dear Mr. Anderson (through your attorney Ms. Lisa Duffee),

As you know, I represent your father-in-law Jerral W. Jones, Sr. He has asked my firm to 

investigate whether he has potential claims against you and others for conversion (extortion) and 

other torts and to determine whether a conspiracy exists among yourself and others including, 

without limitation, certain of your lawyers. In that regard we believe that certain exceptions to the 

attorney client, common interest and attorney work product privileges may apply so please do not 

destroy any communications in any form with your counsel or others under the assumption that 

such privileges apply. 

As of this date you and your counsel can reasonably anticipate litigation even though our 

investigation is not yet complete. Therefore we demand that you preserve all communications in 

any form regarding the matters outlined below (“Preservation Topics”) and that you immediately 

image your personal devices such as cell phones, tablets, computers or other electronic devices of 

any kind in order to preserve material to date. We also demand that you not delete any information 

in the future until this matter is resolved and this includes any form of communication through the 

electronic devices outlined above.

The law imposes on you a duty to preserve materials that are potentially relevant to the 

Preservation Topics. You and all other individuals working for, on behalf of, or associated with 

you, are hereby instructed to not destroy any data or documents related in any way to the above 

matters. This includes, without limitation, all letters, correspondence, emails, text messages, phone 

records and messages, notes, or any other communications. And merely relying on whatever 

preservation steps (if any) you have taken during existing proceedings would not satisfy the 

preservation duty you have related to the issues set out in this notice. A non-exhaustive list of 

reasonable steps would include at a minimum: immediately issuing a hold notice to relevant 

custodians; following up with them to ensure they have complied with the notice; engaging with 

information technology personnel to determine where relevant information is stored; and working 

Charles L. Babcock

(214) 953-6030 (Direct Dial)

(713) 752-4560 (Direct Fax)

cbabcock@jw.com

App. 063

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March 10, 2022

Page 2

with human resources and computer forensics professionals to ensure that information maintained 

by any affiliated persons or entities is properly preserved. The scope of your preservation 

obligations continues until resolution of the controversy, and you should monitor ongoing 

compliance with your preservation obligation.

Preservations Topics are as follows:

1) All efforts to obtain monies from Mr. Jones directly or indirectly through the divorce

proceedings with his daughter and your wife Charlotte;

2) All efforts to obtain monies from Mr. Jones directly or indirectly; 

3) All efforts to obtain information you and/or your counsel consider embarrassing to Mr. 

Jones;

4) The circumstances under which you or your counsel obtained the confidential 

document introduced at his deposition as Exhibit JWJ 319;

5) All communications with Andrew Bergman concerning my client and/or any member 

of Mr. Jones’ family;

6) All communications with or about Cynthia Davis-Spencer who at one time may have 

been known as Cynthia or Cindy Davis;

7) All communications with any person about Mr. Jones during the pendency of your 

divorce proceedings including, without limitation, communications with Carrie Keep;

8) All communications with Alexandra Davis or her current or former employer;

9) All communications with any person regarding an incident with certain Dallas 

Cowboys cheerleaders which was the subject of an article by ESPN; and 

10) All communications with or regarding Vincent Thompson or his representatives.

Thank you for your attention to this matter.

Very truly yours,

Charles L. Babcock

CLB: smz

App. 064

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