Pursuant to CPLR 3126(1), the imposition of sanctions against the party from whom discovery is sought requires a pattern of deliberate, contumacious delay, as opposed to aberrant behavior where there otherwise is substantial compliance with discovery demands or a failure to comply based on a mistaken interpretation of what was required to be produced.
Sherman v. Zampella, NY Slip Op 06397 (1st Dep't November 20, 2025)
