In Naughton v. Bankier, 114 Md. App. 641, 654, 691 A.2d 712 (1997), the Court reversed a sanction of $350 in attorneys' fees levied on a party for the failure of his insurance company to send an agent to a settlement conference. In Naughton, the Court did not address the circuit court's authority to sanction a party for the violation of a Rule 2-504 scheduling order by an insurer. Rather, the court's holding was confined to the propriety of "the settlement judge's imposition of attorney's fees" as a sanction. Id. at 659. The Court observed that, although scheduling orders should not be applied in a manner that is "unyieldingly rigid," litigants must make good faith and reasonable efforts to substantially comply with the court's deadlines: Though such scheduling orders are generally not unyieldingly rigid as extraordinary circumstances which warrant modification do occur, they serve to light the way down the corridors which pending cases will proceed. Indeed, while absolute compliance with scheduling orders is not always feasible from a practical standpoint, we think it quite reasonable for Maryland courts to demand at least substantial compliance, or, at the barest minimum, a good faith and earnest effort toward compliance.