party asserts claim in Georgia

2026And OCGA § 9-15-14(b) permits a trial court to award attorney fees if a party brings an action that “lacked substantial justification[,]” “was interposed for delay or harassment,” or “unnecessarily expanded the proceeding by other improper conduct[.]” “[A]n order awarding attorney fees pursuant to [OCGA § 9-15-14] must specifically state whether the award is made under OCGA § 9-15-14(a) or (b),” Woods v. Hall, 315 Ga. App. 93, 97 (2) ( 726 SE2d 596 ) (2012) (citation and punctuation omitted), and it must include “findings 6 of fact that specify the conduct upon which the award is made[,]” Hick

2026And OCGA § 9-15-14(b) permits a trial court to award attorney fees if a party brings an action that “lacked substantial justification[,]” “was interposed for delay or harassment,” or “unnecessarily expanded the proceeding by other improper conduct[.]” “[A]n order awarding attorney fees pursuant to [OCGA § 9-15-14] must specifically state whether the award is made under OCGA § 9-15-14(a) or (b),” Woods v. Hall, 315 Ga. App. 93, 97 (2) ( 726 SE2d 596 ) (2012) (citation and punctuation omitted), and it must include “findings 6 of fact that specify the conduct upon which the award is made[,]” Hick

2016Land v. State of Ga., 265 Ga. App. 859 ( 595 SE2d 540 ) (2004); Sanders, supra at 425-426 (2) (regarding Fifth Amendment); Simpson v. Simpson, 233 Ga. 17, 19-20 ( 209 SE2d 611 ) (1974) (permitting unfavorable inference to be drawn in civil cases from a privileged refusal to testify, where witness claims privilege embodied in Georgia statutes — such as former Ga. Code § 38-1205, which provided that no party shall be required to testify as to certain matters; the court’s analysis was not limited to cases in which a party asserts a privilege not to answer questions that have a direct tendency to

2016The burden is on the individual claiming the privilege “to state the general reason for his refusal to answer and to specifically establish that a real danger of incrimination existed with respect to each question.” Jett, supra at 656 (2), citing Petty v. Chrysler Credit Corp., 169 Ga. App. 418 ( 312 SE2d 874 ) (1984) (citations and punctuation omitted).

2016Land v. State of Ga., 265 Ga. App. 859 ( 595 SE2d 540 ) (2004); Sanders, supra at 425-426 (2) (regarding Fifth Amendment); Simpson v. Simpson, 233 Ga. 17, 19-20 ( 209 SE2d 611 ) (1974) (permitting unfavorable inference to be drawn in civil cases from a privileged refusal to testify, where witness claims privilege embodied in Georgia statutes — such as former Ga. Code § 38-1205, which provided that no party shall be required to testify as to certain matters; the court’s analysis was not limited to cases in which a party asserts a privilege not to answer questions that have a direct tendency to

2016Land v. State of Ga., 265 Ga. App. 859 ( 595 SE2d 540 ) (2004); Sanders, supra at 425-426 (2) (regarding Fifth Amendment); Simpson v. Simpson, 233 Ga. 17, 19-20 ( 209 SE2d 611 ) (1974) (permitting unfavorable inference to be drawn in civil cases from a privileged refusal to testify, where witness claims privilege embodied in Georgia statutes — such as former Ga. Code § 38-1205, which provided that no party shall be required to testify as to certain matters; the court’s analysis was not limited to cases in which a party asserts a privilege not to answer questions that have a direct tendency to

2003“Inherent in a ruling of the trial court denying attorney fees under OCGA § 9-15-14 (a) is a determination that there does not exist such a complete absence of any justiciable issue of law or fact that it could not be reasonably believed that a court would accept the asserted claim, defense, or other position.” (Emphasis in original.) Hyre v. Denise, supra at 556 (10) (b).

1993Haggard v. Bd. of Regents &c. of Ga., 257 Ga. 524, 527 (4) (c) ( 360 SE2d 566 ) (1987).

1993Haggard v. Bd. of Regents &c. of Ga., 257 Ga. 524, 527 (4) (c) ( 360 SE2d 566 ) (1987).