Text Messages, Slack, and Teams Evidence: From Preservation Through Trial Without Sanctions

Angie Nolet, Esq., CEDS, CIPP, Vice President of Consulting & Information Governance | TransPerfect Legal Solutions

Angie Nolet is a Vice President at TransPerfect Legal Solutions in the company’s Consulting & Information Governance group. An attorney and Certified E-Discovery Specialist based in Seattle, Washington, she previously served as Senior Corporate Counsel of Litigation and eDiscovery at a national, publicly traded technology company, where her responsibilities covered litigation and electronic discovery.

• Education & Credentials

Ms. Nolet earned her Juris Doctor from the University of Washington and her bachelor’s degree from the same institution. She holds the Certified E-Discovery Specialist (CEDS) credential from the Association of Certified eDiscovery Specialists as well as the CIPP designation.

• Recognition & Leadership

In 2023, Ms. Nolet was a finalist for the Financial Times Innovative Lawyer (North America) award for outside counsel management. In 2020, she was named one of Best Lawyers’ Ones to Watch.

• Professional Involvement

Ms. Nolet co-founded and co-hosts eDiscovery Chicks, a podcast about eDiscovery and legal technology, and has moderated industry programs on deploying artificial intelligence in eDiscovery workflows. She has served as a Trial Advocacy Fellow at the University of Washington School of Law, on that school’s Moot Court Honor Board Advisory Committee, and on the King County Washington Women Lawyers Board.

• Experience

Ms. Nolet’s career spans in-house, law firm, and government practice with a sustained focus on litigation and electronic discovery. As Senior Corporate Counsel of Litigation and eDiscovery, she handled litigation and eDiscovery matters for a national, publicly traded technology company. Before moving in-house, she was a trial lawyer at Lane Powell, where she specialized in commercial litigation of design-build disputes. Earlier, she served as a Deputy Prosecuting Attorney at the King County Prosecuting Attorney’s Office in Seattle, where she specialized in gang-related crimes.

Jon Langton, Vice President, Forensic Technology & Consulting | TransPerfect Legal Solutions

Jon Langton is Vice President, Forensic Technology & Consulting at TransPerfect Legal Solutions, where his work has centered on the forensic collection of cloud-based and chat-platform data for corporate eDiscovery, including ephemeral messaging applications, and on rendering that data into formats compatible with legal review platforms.

• Education & Credentials

Mr. Langton earned his bachelor’s degree in 2013 and his master’s degree in 2014 from DeSales University.

• Recognition & Leadership

At TransPerfect Legal Solutions, Mr. Langton has managed a team of eight forensic examiners in the company’s New York forensic laboratory and has contributed to the daily operations of its global Forensic Technology & Consulting division.

• Professional Involvement

Mr. Langton has appeared as a guest on an International Legal Technology Association podcast episode on forensic collections in a work-from-home world, discussing remote data acquisition considerations and logistics, and has been interviewed by Forensic Focus on cloud collections in eDiscovery. He presented at the 2025 Techno Security & Digital Forensics Conference on iOS voicemail data persistence in digital investigations.

• Experience

Mr. Langton’s forensic practice has emphasized the acquisition of cloud-based and message-application data, including sources such as Telegram, using API-based collection approaches adapted to frequently changing platform APIs and varying metadata retention policies. His team’s workflows focus on normalizing emergent and unstructured data sources so they can be reviewed and produced through traditional legal review platforms. He began in digital forensics as the first intern at the Officer David M. Petzold Digital Forensics Laboratory in Center Valley, Pennsylvania, the digital forensic laboratory for the Lehigh County District Attorney’s Office, where he helped extract navigation-device data that connected a vehicle to approximately sixty copper pipe theft cases across eastern Pennsylvania. He was hired by the District Attorney’s Office after his internship and worked for the Lehigh County Computer Crimes Task Force until 2017.

SESSION 1 – Preserving Text and Chat Evidence Before Spoliation Sanctions Hit | 12:00pm – 1:00pm

This session covers the legal framework governing preservation of text messages, Slack, Teams, and ephemeral messaging platforms from the moment the duty to preserve arises through litigation hold implementation and compliance auditing. Attorneys will examine controlling case law under Rule 37(e), the 2024 FTC/DOJ joint guidance, and SEC enforcement data to understand when preservation obligations attach and what steps are legally required. Participants will leave with a concrete framework for issuing platform-specific litigation holds, managing personal-device custodians, and avoiding the most common mistakes that have produced nine-figure sanctions.

BREAK | 1:00pm – 1:10pm

SESSION 2 – Compelling, Producing, and Presenting Chat Evidence at Trial | 1:10pm – 2:10pm

This session covers the full lifecycle of chat-platform ESI from motion to compel through jury presentation, focusing on Microsoft Teams, Slack, and text messages. Attorneys will learn how to frame proportionality arguments under current case law, negotiate production formats that preserve threading and metadata, authenticate digital chat evidence under FRE 901 and 902(14), overcome hearsay objections, and display chat exhibits effectively at trial. Participants leave with a litigation-ready framework for every stage of the discovery-to-verdict process for chat evidence.