1. In Charles Oakley v. MSG Networks, Inc. , No. 17-cv-6903 (RJS), 2025 WL 2061665 (S.D.N.Y. July 23, 2025), U.S. Circuit Judge Richard J. Sullivan (sitting by designation) addressed the appropriate sanctions for alleged spoliation of text messages.

Plaintiff Charles Oakley, a former player for the New York Knicks, brought this action against Defendants for defamation, libel, slander, assault, and battery in connection with an alleged altercation that he had with security at Madison Square Garden (MSG) when he was removed from MSG during a Knicks game on February 8, 2017. Id. at *1.

On July 10, 2024, after the start of discovery, Oakley’s counsel discovered that all text messages sent to or from Oakley’s phone prior to February 2022 had been destroyed. Id. at *2. Oakley claimed tha

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