Local 100 Hotel Employees and Restaurant Employees International Union vs. join the Local Union 100
defamatory leaflets To: Met We are suing you for your And for your false pamphlets inter alia tortious interference trade libel trespass and also prima facie tort unlawful boycotting
Utter and complete disregard for the rules of the truth-seeking process in civil discovery. Court says about Local 100:
ZZZz Repeatedly declared that discovery was complete 1 Did not follow up while client conducted discovery 2 Did not supervise non-attorney client employee who led discovery efforts 3
4 Did nothing about knowledge that client files were in disarray and lack of retention policy
Replaced computers after receiving notice of intent to acquire forensic images 5 Indicated that ordered-deponent was unavailable because of air travel Deponent was in town, at a football game 6 7 Failed to conduct discovery around several important witnesses.
8During deposition, client lied about existence of important activity logs
Counsel Client Boss Client Manager Client Staff e-discovery ball
FRCP Rule 26 FRCP Rule 37 28 U.S.C.  1927 Court's inherent power We request judgment and attorney's fees