A Manhattan appeals court has upheld an $18,000 sanction against two attorneys for their conduct during a deposition.
“We have reviewed the entire deposition transcript and find it replete with instances of conduct ‘undertaken primarily to delay or prolong the resolution of the litigation, or to harass or maliciously injure another,’” a unanimous panel of the Appellate Division, First Department, said, citing New York’s Uniform Rules for the Conduct of Depositions.