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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.

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