Sanctions Denied Because of Lack of Prejudice, Despite Breach of Duty to Preserve Video
E-Discovery LLC
JUNE 16, 2025
Although the Fourth Circuit permits a rebuttable presumption of relevance where willfulness or bad faith is shown, Ms. Moore claimed the missing video was objective evidence that “could corroborate or refute” the parties’ testimony, she offered no particularized evidence that the footage would have supported her claim. Although Ms.
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