Citibank v. Super Sayin Publishing (Southern District of NY, 2017)
Key Insight: Updated spoliation rule was correctly applied to motion regarding earlier conduct because the party cited the updated rule
Nature of Case: Negotiable instrument
Electronic Data Involved: deleted electronic records, emails, text messages
Keywords: retroactive application discovery rule, ESI spoliation sanctions
Identified Local Court Rule(s): S. District N Local Civil Rule 7.1(a)(1)