9:12-cv-03641-SB

Date Filed 09/13/13

Entry Number 32

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA BEAUFORT DIVISION

ROBERT MARK STROUD Plaintiff, v. WELLS FARGO BANK, N.A., SCOTT ZARDENETTA and CHUCK OWENS, Defendants.

) ) Civil Action No.: 9:12-cv-03641-SB ) ) ) PLAINTIFFS MOTION FOR ) SANCTIONS AND TO STRIKE WELLS ) FARGOS ANSWER ) ) ) ) )

or as soon thereafter as this matter may be heard, the undersigned shall move before the

YOU WILL PLEASE TAKE NOTICE that, on the tenth (10th) day after service hereof

Honorable Sol Blatt, Jr., United States District Judge for the District of South Carolina,

pursuant to the holding in U.S. v. Shaffer Equip. Co., 11 F.3d 450, 462 (1993) and Rule 37 imposition of other and additional appropriate sanctions against the defendants. action, Wells Fargo representatives

Federal Rules of Civil Procedure, for an Order striking Wells Fargos defenses and/or for the The grounds for this motion are that with knowledge of the within pending civil intentionally and/or negligently destroyed

information and evidence which they had a duty and obligation to preserve at the time of destruction. This Motion is supported by the Memorandum of Law and its attachments which are submitted contemporaneously herewith.

9:12-cv-03641-SB

Date Filed 09/13/13

Entry Number 32

Page 2 of 2

LAUGHLIN & BOWEN, P.C.

September 13, 2013

By: s/John R.C. Bowen John R.C. Bowen Federal ID# 1403 P.O. Box Drawer 21119 Hilton Head, South Carolina 29925-1119 Telephone: 843-689-5700 Facsimile: 843-689-9300 john@laughlinandbowen.com