On March 20, 2025, the First Department issued a decision in Continuum Energy Tech., LLC v. Iron Oak, Inc. (USA), 2025 NY Slip Op. 01711, affirming a discovery sanction for a late night document dump made after the deadline for document production, explaining:
The court did not abuse its discretion by sanctioning defendants Iron Oak, Inc. (USA), formerly Iron Oak LLC, CETech Holding Ltd., and Rajiv Gosain (the Iron Oak defendants). Plaintiffs served discovery requests in February 2022. The Iron Oak defendants’ responses were due the following month, but they did not respond until October 31, 2022, after regular business hours, with a “data dump.” In addition, the Iron Oak defendants violated the July 2022 preliminary conference order, which required them to respond by October 14, 2022.