A corporation will be held accountable for its lawyer having removed from its accountant’s office records that were about to be produced under subpoena.

U.S. Magistrate Judge Michael Hammer had “little difficulty” deciding the plaintiff in Fairview Ritz Corporation v. Borough of Fairview, 09-cv-0875, had committed spoliation, stating “it is clear that Plaintiff and its counsel acted intentionally or knowingly in keeping the document from Defendants.”