Mealey's (May 3, 2018, 2:59 PM EDT) -- RICHMOND, Va. — A federal judge in Virginia on May 1 ruled that an interior door skin manufacturer failed to show that sanctions for spoliation of evidence against a former employee are warranted because, although the former employee had a duty to preserve certain electronically stored information (ESI) he deleted prior to the litigation, the company has not shown that the ESI is unrecoverable (Steves & Sons Inc. v. JELD-WEN Inc., No. 16-0545, E.D. Va., 2018 U.S. Dist. LEXIS 74460)....