9 : Deadline File

Potential sanctions for improper certification or failure to sign discovery documents. Strategic Considerations

: Filing a motion to dismiss at or before the time of the answer can result in a 90-day stay of discovery in Georgia state court.

The court (e.g., dismissing your defense or claim). 9 : Deadline

: When counting days, usually you exclude the day of the triggering event and include the last day unless it falls on a weekend or legal holiday.

An order to pay and attorney’s fees incurred by the other party. Potential sanctions for improper certification or failure to

: If you are a defendant and the request was served with the summons and complaint, you have up to 45 days to respond.

Under O.C.G.A. § 9-11-12 , failing to obey a court order regarding production can result in: : When counting days, usually you exclude the

: A party served with a request for production must generally serve a written response within 30 days after service.