California, United States of America
The following excerpt is from Coprich v. Superior Court, 80 Cal.App.4th 1081, 95 Cal.Rptr.2d 884 (Cal. App. 2000):
5. The Fourth District Court of Appeal recently reached the same conclusion in a third party negligent spoliation case in an opinion published after oral argument in this case. (See Farmers Ins. Exchange v. Superior Court (2000) 79 Cal.App.4th 1400.
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