Antonio v. Sec. Servs. Of Am., LLC, 2010 WL 2858252 (D. Md. July 19, 2010)

Key Insight: Where defendant failed to preserve relevant computers during its consolidation of operations and failed to preserve data during conversion of it?s IT network, the district court overruled defendant?s objection to the magistrate judge?s finding that the spoliation was ?more than grossly negligent? and the imposition of an adverse inference but sustained defendant?s objections ?to the extent that the finding that the spoliation was more than grossly negligent [was] based on defendant?s limited production of emails, missing personnel record, and untimeliness in participating in discovery ? actions that ?do not indicated willful or intentional spoliation of evidence?

Electronic Data Involved: Computers/hard drives, ESI