Rhoda v. Rhoda (S.D.N.Y., 2017)
Key Insight: which version of FRCP 37(e) should be applied where the issue was raised before the new version became effected but the motion was filed, whether after its effective date?
Nature of Case: employment
Electronic Data Involved: email
Keywords: adverse instruction, intent to deprive, duty to preserve, culpability, web hosting, relevance, prejudice