Notes to 1969 Amendment of Super. R. Civ. P. 34 ("[ujnwarranted objections are made subject to the peril that costs and expenses will be charged against the recalcitrant party or his counsel under Rule 37(a)”). Here, however, the objection was not unwarranted as indicated by the court's denial of D’Amario's previous motion to compel. 10 .In 1993, subdivision (d) of Fed.R.Civ.P. 11 was added expressly to exclude discovery requests, responses, and objections from its provisions. However, prior to the amendment of Federal Rule 11, federal courts recognized that Rule 26(g) was the appropriate certification rule to apply with respect to discovery requests, responses, and objections. See, e.g., United Missouri Bank of Kansas City v. Bank of New York, 723 F.Supp. 408, 414 (W.D.Mo.1989) (<HOLDING>); see also In re Yagman, 796 F.2d 1165, 1187
holding rule 11 sanction proceeding was exempt from automatic stay holding that the term other papers as defined in federal rules 7b2 and 11 refers to discovery motions interrogatories and requests for production and admissions and the responses thereto holding that rule 11 is not properly used to sanction the inappropriate filing of papers where other rules more directly apply holding rule 11 sanction of 20000 to be excessive and reducing to 6500 holding that rules of contract construction are to be applied where the language used is ambiguous