By William A. Ruskin
On February 28, 2012, the Appellate Division, First Department, issued its decision in U.S. Bank N.A. v. GreenPoint Mortgage Funding, Inc ., 2012 N.Y. App.Div. LEXIS 1487 [ enhanced version available to lexis.com subscribers ]...
New York state courts are increasingly turning to federal Zubulake standards [ enhanced version available to lexis.com subscribers ] when confronted with spoliation of electronic evidence issues. However, in dealing with garden variety spoliation of evidence...