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ADVERSE INFERENCE
STANDARD OF REVIEW = ABUSE OF DISCRETION

We review for abuse of discretion the district court’s decision whether to draw an adverse inference based on destruction of evidence. Stevenson v. Union Pac. R.R. Co., 354 F.3d 739, 745 (8th Cir.2003). An adverse inference is appropriate only when, among other things, the party seeking the inference can show that once-extant records were destroyed “to suppress the truth,” and that the records would have favored its case.
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