t is a well-known fact that there are problems with electronic discovery and the storageof electronic information (ESI). An obligation to preserve all "relevant documents" (Landau,2023, if litigation is reasonably foreseeable, this process is called spoliation. There are manyproblems with ESI and spoliation. There has been a recent amendment to the Federal Rules ofCivil Procedure No. 37, wherein it tries to deal with these problems. A court can issue sanctionsif a party has been found guilty of failing to take reasonable steps to preserve ESI. As a result, acourt may order measures "no greater than necessary to cure the prejudice". In addition, thesesanctions can result in an involuntary dismissal of ta Plaintiff's claim and a default judgmentagainst the defendant if it is found that the wrongdoer acted "intentionally" in destroying ESI. Inthe case of Mueller v. Swift (2017) sanctions were issues, as it found that Mueller failed to takereasonable steps to preserve information