A brief opinion on misbehavior during a deposition. In a personal injury case, Plaintiff’s counsel Brett Donaldson instructed his client not to answer questions regarding citations for the accident. Donaldson then argued with defense counsel and cast aspersions on her. When the issue came before the trial court, Donaldson’s behavior had not improved, and he continually interrupted the trial court. The trial court issued sanctions and ordered a second deposition. Donaldson then filed a special action challenging the sanctions. The court of appeals accepted jurisdiction, denied relief, and affirmed the sanctions. Since this is a published opinion, Donaldson has now enshrined his bad behavior and hubris.

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