PARTY’S DELETION OF FACEBOOK PAGE FOUND TO BE SPOLIATION OF EVIDENCE  
A personal-injury plaintiff who deleted his Facebook account while the defendants were trying to access it has been sanctioned for spoliation. The plaintiff “had a duty to preserve his Facebook account at the time it was deactivated and deleted” and the defense would be prejudiced by loss of the evidence U.S. Magistrate Judge Steven Mannion ruled Monday in Gatto v. United Airlines, 10-cv-1090. But Mannion, who sits in Newark, declined a request for legal fees, finding the adverse-inference jury instruction he ordered was a sufficient penalty.