— 15% less negligent than the arbitrators found. A final judgment was entered awarding the Hermans $645,000 above the $860,000 arbitration award, plus prejudgment interest and costs. One of Continental’s contentions in this appeal, and the only one we address, is that Herman had no cause of action for destruction of evidence because she was not, as a result of the destruction, deprived of an opportunity to fully and successfully present a personal injury claim. Herman responds that she need show only that she was “hindered” in presenting her uninsured motorist claim as the essential element to the second tort action. Destruction of evidence, as an independent cause of action, has been recognized in recent cases of this court. Bondu v. Gurvich, 473 So.2d 1307 (Fla. 3d DCA 1984) (<HOLDING>), rev. denied, 484 So.2d 7 (Fla.1986); Miller
recognizing negligent procurement to be a negligence cause of action recognizing the cause of action recognizing negligence cause of action for failure to maintain medical records preservation of which was required by statute recognizing cause of action holding failure to check medical records of inmate that eventually died to be mere negligence