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Woodham v. Atlanta Dev. Auth.

The evidence supported the contempt order entered against an attorney who wilfully failed to comply with two post-judgment discovery orders, but the trial court was not authorized to make the attorney's payment of legal fees and costs a condition for purging contempt, since those fees and costs were not part of a previously-ordered award.

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These related appeals arise from an attempt by Atlanta Development Authority the Authority to conduct discovery in connection with collecting a judgment against attorney John F. Woodham and Citizens for Ethics in Government, LLC Citizens. Woodham represents himself pro se and also represents Citizens.

Woodham is the sole appellant in Case No. A15A1034. He challenges the trial court’s denial of his motion to recuse, but his motion did not meet the threshold requirements of Uniform Superior Court Rule 25.3; accordingly, we affirm that ruling. He also challenges the trial court’s authority to compel post-judgment discovery from him, but he waived appellate review of that challenge by consenting to the discovery. And he challenges the trial court’s order finding him in contempt for wilfully failing to comply with two post-judgment discovery orders. The evidence supports the finding of contempt, which we affirm. However, we reverse as an improper penalty that portion of the contempt order requiring Woodham to pay legal fees and costs to purge the contempt, because the fees and costs were not part of a previously-ordered award.

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