White Out

In a matter involving “exceptionally contentious” post-divorce proceedings, the Wyoming Supreme Court imposed a suspension of 120 days for discovery misconduct.

Respondent’s client had filed a petition to modify custody and visitation.

After issuing a subpoena for medical records, opposing counsel learned that Respondent had whited out portions of documents and failed to produce other documents sought by counsel

Respondent acted with knowledge that she redacted and altered documents with the knowledge she was unilaterally determining relevance of medical records and concealing them from the opposing party in a way that it was not apparent that an alteration or redaction had occurred.

The sanction was influenced by “numerous mitigating factors.” (Mike Frisch)