In addition to the contempt sanctions under Rule 45(g), practitioners should be mindful of the courts’ inherent authority to award attorney fees for willful misconduct. ABA Litigation – Pretrial Practice & Discovery Section (November 2019) located at https://www.americanbar.org/groups/litigation/committees/pretrial-practice-discovery/practice/2019/going-outside-the-rules-to-keep-fees-on-the-table-under-rule-45g/