Supreme Court of Georgia
Workman v. Rl Bb Acq I-Ga Cvl, LLC
May 21, 2018814 S.E.2d 696
Summary
The court held that attorney fees under OCGA § 9-15-14 may be available for improper conduct during post-judgment discovery, but that statute authorizes recovery only by or against parties, so the nonparty appellants could not recover under it. The court also held that a party obtaining a protective order need not request expenses simultaneously and may seek them later under OCGA § 9-11-37 (a) (4) (A). It therefore affirmed in part and reversed in part, while declining to consider a third issue.