Spoliation and Facebook: Don't Toss that "Page" During Litigation.

The article cites the rulings issued by U.S. federal district courts in several cases, notably Gatto vs. United Airlines Inc. and Allied Concrete Co. vs. Lester, which illustrate how the deletion of Facebook pages or other electronically-stored information (ESI) while litigation is pending could leave trial lawyers open to charges of spoliation. However, it adds that any party seeking spoliation sanctions must establish that the deletion of ESI was committed with a "culpable state of mind."