In re Nat. Fin. Enter., Inc. Fin. Inv. Litig., 2009 WL 87618 (S.D. Ohio Jan. 8, 2009)

Key Insight: Where party failed to provide adequate explanation for non-disclosure of relevant email and engaged in other questionable behavior, including providing evasive responses to deposition questions, but where scope of prejudice to opposing party was ?not clear,? court declined to impose dispositive sanctions but ordered discovery re-opened to allow deposition regarding the email and surrounding issues