In re Shawe & Elting LLC, No. C.A. 9661-CB (Delaware Chancery, 2016)

Key Insight: Sanctions for attorney’s fees are warranted when computer files are deleted (even if they are recovered) and when a phone is recklessly lost in a “palpably suspicious” incident.

Nature of Case: Corporate management disputes between co-founders

Electronic Data Involved: cell phone contents, computer files

Keywords: spoliation, palpably suspicious, lost phone, ineffective spoliation, reckless failure to preserve

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