Holding that dismissal is a draconian sanction that "should be employed sparingly and only when there is a record of delay, contumacious conduct, or when other, less drastic sanctions prove unavailing"
Fed. R. Civ. P. 34 Cited 13,452 times 152 Legal Analyses
Finding that the rules related to electronic discovery were "not meant to create a routine right of direct access to a party's electronic information system, although such access may be justified in some circumstances."