271 F.R.D. 13, 24 (S.D.N.Y.2010) (noting that failure to suspend “any routine document destruction or other processes involved in the ordinary course of business that might result in the destruction of potentially relevant evidence” may result in sanctions); see also Victor Stanley Inc. v. Creative Pipe, Inc., 269 F.R.D. 497, 542-553 (D.Md.2010) (comparing the various approaches taken by the United States Circuit Courts of Appeal). 50 . See Fed.R.Civ.P. 26(b)(2)(B) (limiting discovery of electronically-stored information to that which is "reasonably accessible”); Rimkus Consult. Grp. v. Cammarata, 688 F.Supp.2d 598, 612 (S.D.Tex.2010) (analyzing the duty to preserve by focusing on proportionality and reasonableness); Zubulake v. UBS Warburg LLC, 220 F.R.D. 212, 216-18 (S.D.N.Y.2003) (<HOLDING>). 51 . Rimkus Consult. Grp., 688 F.Supp.2d at
recognizing that the corporation is always deemed to be an indispensable party in a shareholder derivative action recognizing a similar exception to its rule with respect to corporations recognizing that a corporation does not have a duty to preserve every data source because such a rule would cripple large corporations  that are almost always involved in litigation holding that while a state statute granted a foreign corporation the rights and privileges enjoyed by domestic corporations it did not transform such corporations into domestic or resident corporations recognizing that when the corporations management or its shareholders are deadlocked with respect to a particular issue courts have realigned such corporations as party plaintiffs