Spoliation and its attendant issues, preservation and cost-shifting, are the big issues of the day. Failing to properly preserve electronic information can carry substantial penalties, as the producing parties (or non-producing parties, as it were) have learned in cases ranging from Linnen v. A.H. Robins , 10 Mass L. Rptr. 189 (Mass. Sup. Ct. 1999) to Zubulake v. UBS Warburg LLC, et al. , Oct. 22, 2003, S.D.N.Y. (Zubulake IV).