摘要：This article evaluates the increased use of counsel sanctions in connection with discovery misconduct in the federal courts. Decisions such as Qualcomm Inc. v. Broadcom Corp. (Qualcomm) have drawn attention to the affirmative responsibilities of counsel for discovery and the ample authority available to sanction them under appropriate circumstances.
关键词：Qualcomm Inc. v. Broadcom Corp.; In re September 11th Liability Insurance Coverage Cases; Zubulake v. UBS Warburg LLC; Cache La Poudre Feeds LLC v. Land O’Lakes Inc; R & R Sails Inc. v. Insurance Co. of Pennsylvania; Board of Regents of University of Nebraska v. BASF Corp.; National Ass’n. of Radiation Survivors v. Turnage; ABA Civil Discovery Standards; State Farm Mutual Automobile Insurance Co. v. New Horizon Inc; Phoenix Four Inc. v. Strategic Resources Corp.; In re Estrada; W.T. Grant Co. v. Haines; Oliveri v. Thompson; Chambers v. NASCO; McGuire v. Sigma Coatings; E.F. Hutton & Co. v. Brown; St. Paul Reinsurance Co. v. Commercial Financial Corp; Link v. Wabash Railroad Co
