“Troubling” Activity with No Proof of Spoliation Insufficient to Warrant Sanctions
HCC Ins. Holdings, Inc. v. Flowers, No. 1:15-cv-3262-WSD, 2017 WL 393732 (N.D. Ga. Jan. 30, 2017)
In this case, the court declined to impose spoliation sanctions, despite Defendant and her husband’s “troubling” behavior, where Plaintiff failed to “present evidence to cast significant doubt” on the explanations for the at-issue behavior and failed to establish that the at-issue information—namely Plaintiff’s trade secrets and confidential information—had ever been “resident” on Defendant’s personal computer or otherwise in her control.