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The Federal Rules provide for sanctions against individual attorneys who are remiss in complying with their discovery obligations: [e]very discovery request, response or objection made by a party ... shall be signed by at least one attorney [and] [t]he signature of the attorney ... constitutes a certification that to the best of the signer's knowledge, information, and belief, formed after a reasonable inquiry, the request, response, or objection is: consistent with the rules and law, not interposed for an improper purpose, and not unreasonable or unduly burdensome or expensive. Fed. R. Civ. P. 26 (g)(2) (emphasis added). '[W]hat is reasonable is a matter for the court to decide on the totality of the circumstances.' Fed. R. Civ. P. 26 Advisory Committee Notes (1983 Amendment). The Committee explained that: Rule 26(g) imposes an affirmative duty to engage in pretrial discovery in a responsible manner that is consistent with the spirit and purposes of Rules 26 through 37. In addition, Rule 26(g) is designed to curb discovery abuse by explicitly encouraging the imposition of sanctions. 


This subdivision provides a deterrent to both excessive discovery and evasion by imposing a certification requirement that obliges each attorney to stop and think ...

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