Opinion here and below. (h/t: How Appealing) The trial court had reviewed depo transcripts well after they had been taken, formed the view that the attorney had been improperly obstructive, and issued a novel sanction (i.e., the attorney was required to produce an instructive video about the ethics of depo behavior) without adequate notice. The appellate court reversed and rather than remand it decided that no further sanctions would be warranted.