In the case of Marinkovic v. Battaglia, No. 1:14-CV-49 (W.D. Pa. Sept. 23, 2019 Baxter, J.), the court granted a Motion to Dismiss after confirming that Pennsylvania law does not recognize any independent cause of action for spoliation. (See Op. at p. 23-29).
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I send thanks to Attorney James M. Beck of the Philadelphia office of the Reed Smith law firm for bringing this case to my attention.