Philmar Dairy, LLC v. Armstrong Farms, No. 18-cv-0530 SMK/KRS (D. N.M. July 11, 2019)

Key Insight: Defendant changed phones and with them photos of fire were lost. Plaintiff requested sanctions due to loss of photos. Court rejects sanction as Defendant could not have known about litigation when phones changed.

Nature of Case: Breach of Contract; Fraud

Electronic Data Involved: Cell Phone Photos

Keywords: spoilation; sanctions

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