In Figdor v. City of New York, A.D.3d 560 (1st Dept 2006) the First Department imposed upon trial courts an affirmative obligation to penalize parties who have frustrated litigation by repeatedly failing to comply with discovery orders. In Figdor, the First Department affirmed a $ 10,000 sanction against the City of New York, where the City failed to respond to discovery orders over a period of two years, noting that documents eventually "trickled in with the passage of each compliance conference."