Tort of Fraudulent Concealment as Cause of Action for Spoliation in New Jersey

From Allia v. Target Corp., 2008 U.S. Dist. LEXIS 29591 (D.N.J. April 10, 2008):

Plaintiff's spoliation of evidence claim must also be dismissed because New Jersey does not recognize spoliation of evidence as an intentional tort. Rosenblit v. Zimmerman, 766 A.2d 749, 757 (N.J. 2001) (stating that spoliation of evidence is not recognized as intentional tort, but that the tort of fraudulent concealment is the remedy for spoliation).

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