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COOK v. CHILDREN'S NAT. MEDICAL CENTER

Civil Action No. 10-0937 (PLF).

810 F.Supp.2d 151 (2011)

Cynthia COOK, Individually and as Mother and Next Friend of LR, a Disabled Person, et al., Plaintiffs, v. CHILDREN'S NATIONAL MEDICAL CENTER, Defendant.

United States District Court, District of Columbia.

September 13, 2011.

Attorney(s) appearing for the Case

John C. Lowe , John Lowe, P.C., Bethesda, MD, Michael Moureau Wilson , Washington, DC, for Plaintiffs.

Ann Michailenko Wilson , Dickie McCamey & Chilcote, Pittsburgh, PA, for Defendant.

OPINION

PAUL L. FRIEDMAN, District Judge.

In Holmes v. Amerex Rent-A-Car, 710 A.2d 846 (D.C.1998), the District of Columbia Court of Appeals recognized a new, independent tort: negligent or reckless spoliation of evidence. See Holmes v. Amerex Rent-A-Car, 710 A.2d at 847-48; see also Mazloum v. District of Columbia Metro. Police Dep't, 522 F.Supp.2d 24

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