Hsueh v. New York State Dep?t of Fin. Servs (Southern District of New York, 2017)
Key Insight: Intentionally deleting ESI is different from failing to preserve and falls under a court’s inherent authority, not FRCP 37(e).
Nature of Case: Sexual harassment
Electronic Data Involved: Recorded conversation
Keywords: Spoliation sanctions, recording, DFS, department of financial services