Washington v. South Georgia Medical Center

I cannot agree that the rule of Singleton v. Eastern Carriers, 192 Ga. App. 227 (384 SE2d 202) (1989), applies to the instant case or to Washington v. South Ga. Med. Center, 221 Ga. App. 640 (472 SE2d 328) (1996). Such rule does not preclude a party from obtaining sanctions against a deponent who fails to appear where the deposition was noticed by another party. Nor do I agree with the majority’s attempt to expand the rule of Singleton; therefore, I must respectfully dissent. The rule in Singleton regarding who may obtain discovery sanctions is limited to written discovery, and the majority’s…