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E-Discovery counsel Samantha V. Ettari’s article, “Can Tests for Spoliation in NY State, Federal Courts be Reconciled?” appeared in the Feb. 6, 2017 issue of the New York Law Journal. The article examines how, with the passage of the December 2015 amendments to the Federal Rules of Civil Procedure, the measure for spoliation and accompanying sanctions in New York state and federal courts for negligent spoliation has diverged.