Parsi v. Daioleslam, 286 F.R.D. 73

Parsi and the National Iranian American Council sues Daioleslam for defamation and false light.
Extensive discovery leads to defendant's omnibus sanctions motion.
Court may sanction under Rule 37 or its inherent authority; Rule 37 has no bad-faith requirement.
Forensic imaging of NIAC's server and calendar data involved multiple imaging rounds.
Court grants some sanctions and fee-shifting but denies others; issues resolved across several categories.
Summary judgment in favor of defendant is issued separately; sanctions decision follows.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Server production and fee-shifting	NIAC complied; imaging costs should be NIAC's responsibility	Defendant entitled to costs for imaging due to omissions	Partial fee-shifting awarded; last two imaging rounds cost borne by NIAC
Calendar entries alterations and deletions	Entries properly produced; alleged edits show misconduct	Entries were altered/deleted to conceal misconduct	No clear preponderance of intentional alteration; not sanctions-worthy as to calendar entries
Talebi emails and related production	Produced under Court orders; search terms adequate	Missed keys terms; significant remaining emails	Defendant awarded some costs; Court granted partial reimbursement for 5500 emails and related deposition expenses
Third-party emails and subpoenas	Full production burdens on NIAC; subpoenas unnecessary	Subpoena costs necessary due to incomplete production	Plaintiffs to bear subpoenas costs; sanctions to deter further nonproduction
Salesforce data and deposition expenses	Nonproduction justified; deposition costs appropriate	Costs warranted due to belated production	Partial deposition-cost sanctions; split difference on extra half-day; expenses awarded for related motion

Pierce v. Underwood, 487 U.S. 552 (U.S. 1988) (substantial justification standard for opposing motions to compel)
Shepherd v. Am. Broadcasting Cos., Inc., 62 F.3d 1469 (D.C. Cir. 1995) (inherent power sanctions for discovery abuses)
Rimkus Consulting Group, Inc. v. Cammarata, 688 F. Supp. 2d 598 (S.D. Tex. 2010) (proportionality in electronic discovery burdens)