The Business Court sanctioned the Defendants in Clark v. Alan Vester Auto Group, Inc., 2009 NCBC 18 (N.C. Super. Ct. July 17, 2009) for spoliation of evidence.

The destruction of evidence involved "Cover Sheets" that the Defendants prepared whenever they sold a car. The Plaintiff contended that an entry on a Cover Sheet referring to "CFA" — which was shorthand for "customer funding assistance" — would have shown the Defendants’ falsification of information regarding the down payment made by the customer.

The Defendants continued to destroy Cover Sheets even

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