买卖合同诉讼保全申请书
    英文回答：
    [Preservation of Evidence Motion in Contract Dispute]
    I. Introduction.
    In the present case, the Plaintiff, [Plaintiff's Name], and the Defendant, [Defendant's Name], entered into a contract for the sale and delivery of [goods/services]. A dispute has arisen regarding the performance of the contract, and the Plaintiff alleges that the Defendant has breached its contractual obligations.
    II. Grounds for Preservation of Evidence.
    The Plaintiff requests the preservation of evidence in this matter because:
    The evidence is relevant and material to the Plaintiff's claims. The evidence includes documents, emails, text messages, and other communications that will prove the Defendant'
s breach of contract.
    The evidence is in danger of being destroyed or concealed. The Defendant has a history of destroying or concealing evidence that is unfavorable to it.
    The Plaintiff has good cause to believe that the Defendant will destroy or conceal the evidence. The Defendant has made threats to destroy or conceal the evidence, and has previously engaged in such conduct.
    III. Scope of Preservation Order.
    The Plaintiff requests that the Court issue a preservation order requiring the Defendant to preserve the following evidence:
    All documents, emails, text messages, and other communications relating to the contract.
    All financial records relating to the contract.
    All physical evidence, such as products, equipment, and materials, that is related to the contract.
    IV. Sanctions for Non-Compliance.
    The Plaintiff requests that the Court impose sanctions on the Defendant for any failure to comply with the preservation order, including:
defendant

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