A model agency motion for discovery sanctions in an appeal before the Merit Systems Protection Board (MSPB) under the Civil Service Reform Act of 1978 (CSRA), the Whistleblower Protection Act (WPA), as amended by the Whistleblower Protection Enhancement Act of 2012 (WPEA), the Uniformed Services Employment and Reemployment Rights Act (USERRA), or the Veterans Employment Opportunities Act (VEOA). This Standard Document applies to federal agency workplaces. It is based on federal law. This Standard Document has integrated notes with important explanations and drafting tips.