NEW YORK - A New York appeals court on Aug. 9 affirmed the dismissal of tenants' mold-related claims against an individual defendant and a decision granting their landlords summary judgment, finding that certain sanctions in relation to the spoliation of evidence against the tenants were warranted (Agnese Ines Theodoli & Phillips H. Clarke III v. 170 East 77th 1 LLC, et al., No. 570128/13, N.Y. Sup., App. Div., 1st Dept.; 2013 NY Slip Op 51310$(U$)).