Archive: October 9, 2006

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Modern Discovery: New Rules, New Approaches
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Ninth Circuit Upholds Dismissal of Complaint and $65,000 Sanction for Spoliation of Computer Files Under Court’s Inherent Authority

Modern Discovery: New Rules, New Approaches

Examine crucial discovery issues facing practitioners today.  Martha Dawson, Program Committee Chair for this WSBA-sponsored CLE, will give an update on the ethical obligations in the complex world of e-discovery on Thursday, October 26, 2006, Seattle Hilton.  Preston partners Helen Bergman Moure and Todd Nunn will moderate separate panels that will explore the ramifications of the new federal rules and the new state rules, both actual and proposed, that relate to litigation and discovery.   Download the event brochure here.

Ninth Circuit Upholds Dismissal of Complaint and $65,000 Sanction for Spoliation of Computer Files Under Court’s Inherent Authority

Leon v. IDX Sys. Corp., 464 F.3d 951 (9th Cir. 2006)

Dr. Mauricio Leon (“Leon”) was hired by the defendant in 2001, and in mid-2002, he began complaining of mismanagement of a federally-funded project.  In April 2003, IDX put Leon on unpaid leave and brought an action for declaratory relief, seeking to establish that it could terminate him without violating the anti-retaliation provisions of the False Claims Act, SOX and the ADA.  In May 2003, Leon filed his own action, which included claims for retaliation under various statutes and state law claims.
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