Padron v. Watchtower Bible & Tract Society of New York
Annotate this CaseThis case presented the issue whether a superior court could impose a hefty daily monetary sanction on a party who steadfastly refuses to comply with a discovery order. The court ordered Watchtower Bible and Tract Society of New York, Inc. (Watchtower) to produce documents responsive to a specific request for production. Per the court's order, the documents would be redacted to protect certain third parties' privacy interests and produced subject to a strict confidentiality and nondisclosure order negotiated by Watchtower. In addition, the court ordered Watchtower to look for documents in files it represented, on multiple occasions, to be in its possession, custody, and/or control. Watchtower informed the court that it would not comply with the order. As such, plaintiff Osbaldo Padron moved for monetary sanctions against Watchtower for its discovery abuses. The court awarded sanctions in the amount of $4,000 per day for noncompliance with the order, and Watchtower appealed that order. Finding that Watchtower took two inconsistent positions as grounds for its argument to reverse the sanction order, the Court of Appeal held Watchtower was judicially estopped from arguing the superior court lacked authority to issue the sanctions. Finding no other reason to reverse, the Court of Appeal affirmed the sanctions.
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