I think (based on seeing how many of these types of messages are coming up in discovery in recent cases) that many people these days don't think of "text messag

I think (based on seeing how many of these types of messages are coming up in discovery in recent cases) that many people these days don't think of "text messages" (email, SMS, WhatsApp, Slack, FB, you name it) qualify as "in writing". Doubtful most people would dare write a printed memo and sign their name to it with the same content that they would write in a text or email.