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    First Department Case Development on the Federal and New York Common Law Spoliation Standards

    Spoliation, or “[t]he intentional destruction, mutilation, alteration, or concealment of evidence,”[1] is a sanctionable offense. However, precisely what constitutes spoliation has created some recent controversy. In October 2013, the First Department of the New York Appellate Division clarified the breadth and application of both the federal and New York common law spoliation standards. In Strong […]