Rialto-BB Acquisition sought post-judgment discovery from Honey Workman and others after obtaining a large deficiency judgment against related debtors. The trial court imposed monetary and non-monetary sanctions, limited a post-judgment deposition, and awarded fees under Georgia’s statute governing litigation lacking substantial justification. The Court of Appeals reversed in part and vacated in part. It held that the fee statute did not apply to post-judgment discovery and that the trial court’s factual findings did not support the sanctions and fee award entered against Rialto and its attorneys. The court also vacated the ruling on a protective-order dispute because the record required further consideration of the parties’ discovery positions. The case was remanded for a new determination consistent with the opinion. The court preserved only rulings supported by the proper discovery standards and left the underlying deficiency judgment undisturbed. Two judges concurred, with one concurring in the judgment only.