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New Rule 37(e) and Inherent Authority: More Ambiguous than Before

Case #1: Hsueh v. New York State Department of Financial Services, 2017 WL 1194706 (S.D.N.Y. Mar. 31, 2017)

Why this Case is Important: Rule 37(e) does not apply when intentional spoliation occurs, empowering the court to use inherent authority to issue sanctions.