The First Department's Jan. 29 ‘spoliation trifecta’
On Jan. 29, 2013, the First Department released three decisions that
addressed issues related to "spoliation" of evidence that, taken together,
constitute a primer on how that Appellate Division approaches both the
claims of loss, destruction or failure to preserve evidence, on the one
hand, and the consequences and sanctions for the negligent or intentional
failure to maintain and produce documentary and other proof, on the other.


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Source:
http://newsandinsight.thomsonreuters.com/New_York/Insight/2013/03_-_March/The_First_Department_s__Jan__29_
‘spoliation_trifecta’/
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