Chi v. Loyola Univ. Med. Ctr., No. 10 C 6292, 2013 WL 422868 (N.D. Ill. Feb. 1, 2013)

Key Insight: Upon a motion to clarify regarding Plaintiff?s prior motion for sanctions for defendant?s failure to preserve backup tapes, the court confirmed that Plaintiff could recover attorney?s fees and expenses ?reasonably incurred as a result of the failure to preserve backup tapes and the resulting discovery? (even where the follow-up discovery necessitated by the failure to preserve was not fruitful), but made clear that the recovery would be limited and that fees and expenses related to the filing and briefing of the motion for sanctions would not be awarded

Nature of Case: Defamation

Electronic Data Involved: Backup tapes