Objectant's motion for a protective order was not frivolous. While the attorney for the 92-year-old objectant can be faulted for twice canceling the deposition within a four-month period, and for offering only an unsworn letter from objectant's physician in support of the motion for a protective order that was made on the day the deposition was to be held, the motion for a protective order clearly was not completely without merit in fact or undertaken primarily to delay,...
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