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Hyland v. Hughes Aircraft Company2/26/2002 r" photographs of trimmed trees]; R.S. Creative, supra, at pp. 488-489 [forged contract attached to complaint].) Discovery sanctions are reviewed under the abuse of discretion standard. (Foothill Properties v. Lyon/Copley Corona Associates (1996) 46 Cal.App.4th 1542, 1557.)
In the instant case, the empty folders plus the few papers relating to senior Hughes executives and the presence of complete records for other employees create an inference of spoliation. The trial court is directed to fashion sanctions appropriate to the dereliction.
DISPOSITION
The judgment is reversed, and the matter is remanded for further proceedings consistent with this opinion. Appellant to recover her costs on appeal.
We concur:
JOHNSON, J.
WOODS, J.
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