There is nothing in the record upon which a reasonable person could
rely to find Sakar’s actions appropriate. Here e.Digital made repeated good faith efforts to afford
Sakar additional time to respond to the discovery requests and to resolve this discovery dispute
prior to invoking the powers of this Court to intervene. On these facts, it is appropriate to
impose the mandatory sanctions of Rule 37 to reimburse e.Digital for this exercise, to penalize
Sakar for its dilatory discovery tactics, and to deter others from engaging in similar conduct.