Small v. University Medical Center of Southern Nevada

2014 WL 4079507 (2014)

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Small v. University Medical Center of Southern Nevada

United States District Court for the District of Nevada
2014 WL 4079507 (2014)

RW

Facts

The federal employment-law litigation that Daniel Small (plaintiff) brought against University Medical Center of Southern Nevada (medical center) (defendant) had been bogged down in discovery for almost two years. The logjam cleared only after it came to light that the medical center kept potentially responsive and discoverable electronically stored information (ESI) on previously undisclosed databases, and that key medical-center employees stored work-related ESI on both their work-issued and personally owned mobile devices. The medical center hitherto had taken no steps to protect these sources of ESI against spoliation.

Rule of Law

Issue

Holding and Reasoning (Garrie, J.)

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