Discovery
Generally
"When reviewing a trial court's ruling on a discovery issue, our Court reviews the order of the trial court for an abuse of discretion. Midkiff v. Compton, 204 N.C. App. 21, 24, 693 S.E.2d 172, 175, cert. denied, 364 N.C. 326, 700 S.E.2d 922 (2010).
Sanctions for Rule 37 Violations
"A trial court's award of sanctions under Rule 37 will not be overturned on appeal absent an abuse of discretion. Graham v. Rogers, 121 N.C. App. 460, 465, 466 S.E.2d 290, 294 (1996).
"'[B]efore dismissing a party's claim with prejudice pursuant to Rule 37, the trial court must consider less severe sanctions.' Global Furniture, Inc. v. Proctor, 165 N.C. App. 229, 233, 598 S.E.2d 232, 235 (2004) (quoting Hursey v. Homes by Design, 121 N.C. App. 175, 179, 464 S.E.2d 504, 507 (1995)).
"[A]s Rule 37(a)(4) requires the award of expenses to be reasonable, the record must contain findings of fact to support the award of any expenses, including attorney's fees. Benfield v. Benfield, 89 N.C. App. 415, 422, 366 S.E.2d 500, 504 (1988).