On September 30, 2020, the court granted Plaintiffs (1) motions to co For full print and download access, please subscribe at https://www.trellis.law/. See CCP 2023.030(e). was convicted of a felony, and that the plaintiff is guilty of fraud, oppression, Failing to confer in person, by telephone, or by letter with an opposing party or attorney in a reasonable and good faith attempt to resolve informally any dispute concerning discovery, if the section governing a particular discovery motion requires the filing of a declaration stating facts showing that an attempt at informal resolution has been made. endstream endobj startxref 4 sufficient to deter repetition of this conduct or comparable conduct by others similarly Creating regulations provide responses in re: requirements in showing that motion for terminating sanctions california rule is in a prolonged vacation to the state environmental laws regarding the. Deyo, supra, 84 Cal.App.3d at p. 787; Fred Howland Co. v. Superior Court of Los Angeles County (1966) 244 Cal.App.2d 605, 610-611. Memorandum of points and authorities with citations to case law and statutory authority. In addition, Defendants Motion to Compel Plaintiffs to Provide Verified Responses to Requests for Pr ..of July 1, 2020 [ ] Late [X] None During argument, counsel for the Sugasawaras twice referred to $1,400 as the amount of sanctions owed to his clients, which "they" had not paid. What Is a Motion for Terminating Sanctions? The court, after notice to any affected party, person, or attorney, and after opportunity for hearing, may impose terminating sanctions against anyone engaging in conduct that is a misuse of the discovery process. Code Civ. Proc., 2023.030. The terminating sanction deprived defendant of the right to defend the lawsuit on its merits and "was one designed not to accomplish the purposes of discovery but designed to punish" the defendant for its omission. A monetary sanction is immediately enforceable as a judgment, unless the court rules that it is not. and belief, formed after an inquiry reasonable under the circumstances, all of the On June 3, 2019, Plaintiffs served a second notice of taking Defendants deposition, but they failed to appear for their depositions. (b), the court may assess punitive damages against the plaintiff upon a determination IVAN MENDOZA ; Plaintiff, vs. orange trim, inc. ; Defendant. by clicking the Inbox on the top right hand corner. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. Fairfield v. Superior Court for Los Angeles County (1966) 246 Cal.App.2d 113, 118. service of the motion, or any other period as the court may prescribe, the challenged Time: 10:00 a.m. The trial judge stopped it by granting the motion to strike and ordering that the Sugasawaras proceed by default. (156 Cal.App.3d at p. so identified, are reasonably based on a lack of information or belief. a pleading, petition, written notice of motion, or other similar paper, an attorney Hearing Date: August 18, 2021 Courts should take an incremental approach, starting with monetary sanctions and ending with terminating sanctions. Last. Who Is At Fault In A Pedestrian Accident In California? DEPT C-20 January 1 201 All counsel are notified that. [ 2023, subd. an order striking out the pleadings or parts of the pleadings of any party engaging in the misuse of the discovery process; an order staying further proceedings by that party until an order for discovery is obeyed; an order dismissing the action, or any part of the action, of that party; or. The motion sought terminating sanctions to dismiss Klimek's 4. Decision on this preclusion of discretion in the sanction provision making the documents to provide a court for the notice with our services to remove this motion for terminating sanctions! 295.). 3d 76, 81 [231 Cal. For requests for admission, see CCP 2033.080, CCP 2033.280, CCP 2033.290, CCP 2033.300, and CCP 2033.420. Case No. Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 128.7 - last updated January 01, 2019 The circumstances warrant our direction to the trial court, by writ of mandate, to set aside the improper order and the resulting default judgment. Evans practice is devoted to serious personal injury claims and catastrophic property damage claims. Seiko Epson Corporation brought suit against multiple individuals for trademark counterfeiting, trademark infringement, and other claims related to nearly $15 million in unauthorized sales of Epson printer cartridges by the defendants and their related companies. Background 5567 0 obj <>/Encrypt 5545 0 R/Filter/FlateDecode/ID[]/Index[5544 307]/Info 5543 0 R/Length 134/Prev 946763/Root 5546 0 R/Size 5851/Type/XRef/W[1 3 1]>>stream Click the on our main page to search for what you are looking for. The theory of the motion was attorney neglect. We have notified your account executive who will contact you shortly. 4th 614], The appellate court found it to be self-evident that an issue sanction would have been sufficient punishment for the inadequacy of defendant's response. The court should begin with lesser sanctions to determine their effectiveness before issuing terminating sanctions. 4th 613] stricken "for failure to timely pay sanctions." 2012 the Court DENIES Defendants' motion for terminating sanctions against. Pendency of the action in California so a valid judgment can unquestionably be obtained in. In the end, the trial judge concluded that the court had "bent over backwards" for Newland and that "the buck's got to stop somewhere." Rptr. Gorman & Miller, John C. Gorman and Catherine L. Chou for Petitioner. JEFFREY M. NEWLAND, Petitioner, v. THE SUPERIOR COURT OF LOS ANGELES COUNTY, Respondent; JIM Y. SUGASAWARA et al., Real Parties in Interest. Motion for Terminating Sanctions 2d 484]. Codes Display Text California Legislative Information. Before any sanctions may be imposed the Court must make an express finding that there has been a willful failure of the party to comply with the Courts discovery order. * concurring.). below, impose an appropriate sanction upon the attorneys, law firms, or parties that On behalf of clients, Evan has fought insurance firms, international companies, cities, bars, and casinos. Citing several United States Supreme Court decisions, the Midwife court concluded that "[c]onstitutional due process 'imposes limitations on the power of courts, even in aid of their own valid processes, to order discovery sanctions that deprive a party of his opportunity for a hearing on the merits of his claim.' by affidavit. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); California Code of Civil Procedure Section 128.5 Sanctions, https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-128-5.html, https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB984, https://www.youtube.com/watch?v=FVLy92G7VVk. Disobeying a court order to provide discovery. 9(1)-92.) (Subd (c) amended effective January 1, 2007; adopted effective July 1, 2001; previously amended effective January 1, 2004.). Aside from the other infirmity of the order, the sanction subjected Newland to a judgment in excess of $220,000 and foreclosed his entire defense, including consideration of his then pending motion for summary judgment, because he was three days late in paying the monetary sanction he owed. (27 Cal.App.4th at p. Here, a party may be prohibited from introducing certain matters into evidence. Judge of the Municipal Court for the Los Angeles Judicial District sitting under assignment by the Chairperson of the Judicial Council. motions or requests and shall describe the specific conduct alleged to violate subdivision 759.) 227] [making no distinction]. 8 To appear for a discovery conference to resolve six motions to compel filed. Despite the extensive sales volume of counterfeit goods that the defendants enjoyed, they repeatedly failed to meaningfully participate in litigation in even the most basic ways. Order Denying Defendants' Motion for Sanctions Against the. Sanctions must not be imposed under this rule except on noticed motion by the party seeking sanctions or on the court's own motion after the court has provided notice and an opportunity to be heard. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-128-7/. 18-15124 & 18-15245 (9th Cir. 3d 57, 63 [249 Cal. Newland's attorney thought his agreement with counsel for the Sugasawaras also postponed the date for payment of the sanctions ordered against his client (which, by then, amounted to $750) to April 21, although no order postponing payment had been made. ********************************* 3. Within the latter are orders striking pleadings, orders staying further proceedings until an order for discovery is obeyed, dismissals, judgments by default, and contempt. Motion for Terminating Sanctions An order staying further proceedings by that party See CCP 2023.030(c). As we have explained, a terminating sanction issued solely because of a failure to pay a monetary discovery sanction is never justified. California Code Code of Civil Procedure CCP 2023030. On March 21, 1995, Newland filed a motion for summary judgment, which he set for 31 days hence, on April 21, 1995. incurred as a direct result of the violation. Stay up-to-date with how the law affects your life. Persisting, over objection and without substantial justification, in an attempt to obtain information or materials that are outside the scope of permissible discovery. Motion for Terminating Sanctions WebDiscovery sanctions are not based on need or ability to pay. WebAside from the other infirmity of the order, the sanction subjected Newland to a judgment in excess of $220,000 and foreclosed his entire defense, including consideration of his then 4th 616] with substantial justification or that other circumstances make the imposition of the sanction unjust." Rptr. Contact Mefor a free consultation. For sanctions on the court's own motion CCP 127c if an attorney or party has. On January 17, 2018, Plaintiff Keoni Huegli (Plaintiff) filed a complaint against Defendants Gerald Peter Fernando and Federal Express Corporation (collectively Defendants) following a motor vehicle colli ..s failure to submit to the examination. Earle & Reimer APC v Klimek CA6 CourtListenercom. NEC 64691, Coleman A. Swart, Judge. This sample opposition to a motion for terminating sanctions in California is filed on the grounds that the opposing party has complied with all discovery orders. Apr 24 2020 California District Judge Edward J Davila granted the plaintiffs' motion for sanctions through FRCP Rules 37b and 37e. See Weil and Brown California Practice Guide Civil Procedure. Even if the motion for sanctions has merit the court must deny the request if the filing party failed to provide the opposing party the 21 day safe harbor notice of their intent to file prior to filing the motion for sanctions. 5544 0 obj <> endobj The terminating sanctions award attorney fees. Subscribe to our newsletter and stay up to date with the latest updates and documents! The basis of the lawsuit is briefly discussed in our earlier opinion arising out of the same litigation, Sugasawara v. Newland (1994) 27 Cal. Insurance Is Law. (Bell v. Superior Court (1906) 150 Cal. Code Civ. Copyright 2023, Thomson Reuters. Let us know about any accessibility problems you encounter using this website. Webfor terminating sanctions and alternative motion to compel Vans appearance at deposition (all of which was included in Language Lines motion) until August 29, If it was improper to terminate a plaintiff's lawsuit or to default a defendant for failure to pay a monetary fine imposed as a result of that party's willful failure to honor the discovery law, as it was, there is even less justification for that sanction under the present scheme where even an innocent violation is subject to monetary sanctions. (CCP 2023.030) WebA limitation on the terms and conditions of the deposition. (Newland had been unemployed for over a year; he would have to post an appeal bond of over $440,000 in order to stay execution on the judgment. In addition to any other sanctions permitted by law, the court may order a person, after written notice and an opportunity to be heard, to pay reasonable monetary sanctions to the court or an aggrieved person, or both, for failure without good cause to comply with the applicable rules. You also need a memorandum of points and authorities and supporting declaration. 1, 1995, and any other pleading, written notice of motion, or other similar paper Making, without substantial justification, an unmeritorious objection to discovery. Also, we don't guarantee, predict, or warrant the outcome of any specific matter. The court may impose terminating sanctions by issuing one of the following orders: an order striking out the pleadings or parts of the pleadings of any party engaging in the misuse of the discovery process; an order staying further proceedings by that party until an order for discovery is obeyed; (b) By presenting to the court, whether by signing, filing, submitting, or later advocating, objections, and motions. They are currently arriving within 30 minutes of purchase. Published on January 2017 | Categories: Documents | Downloads: 292 | Comments: 0 | Views: 819. He also contributes to various podcasts and publications. Hearing Date: August 30, 2019 They were, instead, "a matter solely for consideration in the lower court." Motion for Terminating Sanctions Proof of Service Filed - Motion for terminating sanctions. The court considered the mo ..operative First Amended Complaint on July 9, 2020, against defendants Orange Trim and Soon Pill Kim. Second Dist., Div. (1) Monetary sanctions may not be awarded against a represented party for a violation You will lose the information in your envelope, Order Filed Re: - DENYING MOTION FOR TERMINATING SANCTIONS, JEFFREY YOUNG -V- CARDINAL HEALTH ET AL (MF) Print, Opposition to Motion Filed - to Motion for Terminating Sanctions, Barmore et al -v- Circa Management, Inc. et al Print. 2-4.) For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. The Law Office of Evan W. Walker is committed to ensuring equal accessibility to our users. or, if imposed on motion and warranted for effective deterrence, an order directing He also spoke of three monetary sanction orders, a further reference to the $700 order against Newland's former attorney for which Newland was not responsible. Deyo, supra, 84 Cal.App.3d at p. 788; Cornwall v. Santa Monica Dairy Co. (1977) 66 Cal.App.3d 250. Rptr. REPLY: None filed as of July 1, 2020 [ ] Late [X] None The $700 monetary sanction was not set aside. 2022 American Bar Association, all rights reserved. Lack of diligence may be deemed willful where the party understood its obligation, had the ability to comply, and failed to comply. Court Reverses Ruling on Terminating Sanctions Tyson. (203 Cal.App.3d at p. ^EjP@2Zk,JP@*g6SD{\'%wm(Ww3i;)na'cSo#?Y~Dnp{jw#Cu?bF w6# \o&uM`[F,oIuJ8H3,@PP\dH~g6T?x:am/mT(Mwk")Y})SZZVF6&_^5`e:>6Vk:k3BeyC@ksE=4n; 9_TWV36p3+K5g%Vw,v8RX5T$ .Mv:Iq[5Pw\R[Fx"V4fkDluI*o[ea7vmyOM{U0)4f&]v07zJ Hon8x Wj ++JqkL!Tp0yu[L~jtx]upnG1(Er. The trial court issued a terminating sanction in light of the fact that its. The Civil Discovery Act of 1986 ( 2016 et seq.) Plaintiff argues that the factors weigh heavily in favor of terminating sanctions. WebTerminating sanctions are not available for failing to respond to requests for admission as the code provides that any requests for admission not properly responded to may be an order rendering a judgment by default against that party. The court, after notice to any affected party, person, or attorney, and after opportunity for hearing, may impose terminating sanctions against anyone engaging in conduct that is a misuse of the discovery process. Heres a brief primer. to show cause why it has not violated subdivision (b), unless, within 21 days of service ANALYSIS: (Z]gt l=z[Ni4[~g~2>Ky/AtT) Plaintiff Mercury Insurance Companys Motions for Terminating Sanctions are GRANTED. Co. v. Superior Court (1985) 171 Cal. This information or any portion thereof may not be copied or disseminated in any form or by any means or downloaded or stored in an electronic database or retrieval system without the express written consent of the American Bar Association. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. There, the court may order that certain facts are taken as established. See CCP 2023.030(b). expenses and attorney's fees incurred in presenting or opposing the motion. Every motion must include a written notice of motion that sets forth when and where the motion will be presented, the grounds on which the motion will be made and the papers on which the motion is to be based. /content/aba-cms-dotorg/en/groups/litigation/committees/pretrial-practice-discovery/practice/2020/case-terminating-sanctions-a-lesson-about-inappropriate-conduct. If a failure to comply with an applicable rule is the responsibility of counsel and not of the party, any penalty must be imposed on counsel and must not adversely affect the party's cause of action or defense thereto. Rptr. (h) A motion for sanctions brought by a party or a party's attorney primarily for an improper purpose, such as to harass or to cause unnecessary delay or needless 5850 0 obj <>stream try clicking the minimize button instead. The representation about unpaid sanctions was inappropriate insofar as the $700 sanction was concerned, since that sanction order was directed against Newland's former attorney, not against Newland. Areas of focus include security claims against bars and other businesses, government tort claims, fire and flood claims, and inverse condemnation. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Current as of January 01, 2019 | Updated by FindLaw Staff. Of California meted out justice by ordering terminating sanctions due to the. its order to show cause before a voluntary dismissal or settlement of the claims made (CCP 2023.030; 2031.300) (Motions, Thai Decl. If warranted, the court may award to the party prevailing on the motion the reasonable Cal. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. Reluctant to impose a terminating sanction unless a history of lesser sanctions. Rule 2.30 amended and renumbered effective January 1, 2007; adopted as rule 227 effective January 1, 1985; previously amended effective January 1, 1994, July 1, 2001, and January 1, 2004. F The First Motion for Terminating Sanctions and the Second. Your content views addon has successfully been added. See Karlsson v. Ford Motor Co. (2006) 140 CA4th 1202. [See 917.1, subds. First, you need to determine the statute allowing discovery sanctions. A Terminating Sanctions Should Not Properly Be Awarded. (2) On its own motion, the court may enter an order describing the specific conduct WebDownload Sample Motion For Terminating Sanctions In California Type: PDF Date: December 2019 Size: 121.8KB Author: Stan Burman This document was uploaded by An order imposing sanctions must be in writing and must recite in detail the conduct or circumstances justifying the order. ], This site is protected by reCAPTCHA and the Google. MOVING PARTY: Plaintiffs Jamie Torres and Aliz Cortez (1) An order striking out the pleadings or parts of the pleadings of any party engaging in the misuse of the discovery process. The next subdivision provides a list of sanctions in graduated severity, beginning with monetary awards and ending with terminating orders. Legal Standard If you are author The court continued the motion to strike to that date, and set a mandatory settlement conference (MSC) to be held on the same day. The court must rule on the motion as if the party had appeared. App. The magistrate judge commented that in 18 years as a judge, she had never encountered th[is] level of obstructionism. Id. Northern California Employment Team Secures Motion for. A terminating sanction is an order striking pleadings in whole or in part or dismissing a motion filed by the party guilty of discovery misuse all together. 4th 615] reasonably related to the purpose of effecting the discovery due." Each paper shall state the signer's address and telephone number, if any. (b). 3d 664, 670 [157 Cal. motion for terminating sanctions This includes failing to respond to an authorized method of discovery and disobeying a court order t KEONI HUEGLI, Plaintiff, v. GERALD PETER FERNANDO, et al., Defendants. Rptr. Contempt and Sanctions Law Library for San Bernardino. 377].) (2) Monetary sanctions may not be awarded on the court's motion unless the court issues * concurred. The extreme sanction of case termination is available when a party obstructs and fails to participate meaningfully in discovery. Document collections are now available as non-refundable purchase items with new pricing. when new changes related to " are available. Plaintiff's Opposition to Defendant's Motion for Terminating. Where a party fails to obey an order compelling answers to discovery, the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction. Superior Court of California Rptr. The reinstated judgment, which had been awarded in January 1993, amounted to $220,739.10 as of that time. On November 29, the trial court ordered Newland to pay the $500 sanction previously imposed against him, together with [40 Cal. And for requests for production, see CCP 2031.060, CCP 2031.300, CCP 2031.310, and CCP 2031.320. Terminating sanctions are the most severe type of discovery sanctions. Code Civ. (Subd (a) amended effective January 1, 2004; adopted effective July 1, 2001.). ), Applying the underlying principles, we held in Motown Record Corp. v. Superior Court, supra, 155 Cal.App.3d at pages 484, 490, that a waiver-of-privilege sanction was excessive "because it is punitive in nature and not [40 Cal. Any information submitted through this site will not be confidential. App 3d 527 527 196 in which the California Court of Appeal held. Petitioner Jeffrey M. Newland is one of the named defendants. CEB is the premier provider of California-specific legal content and analysis. Spoliation by Self-Driving Startup Leads to Terminating. Mended that the motion for terminating sanctions be granted. ), [2] [1b] The rule that a sanction order cannot go further than is necessary to accomplish the purpose of discovery is some 35 years old in California, and is rooted in constitutional due process. TENTATIVE RULING: Accessing Verdicts requires a change to your plan. Evidence sanctions are another type and are similar to issue sanctions. or to cause unnecessary delay or needless increase in the cost of litigation. 3d 754 [203 Cal. Notice of motion shall be served as provided in Section 1010, but shall not be filed with or presented to the court unless, within 21 days after The download manager is not working as well as usual. (See, CCP 128.5 (f)(1)) Accordingly, the Motion for Sanctions must be made separately from all other motions and must describe in detail the action or tactic that was made in bad faith that is frivolous or solely initiated to cause unnecessary delay. ), (Opinion by Epstein, Acting P. J., with Vogel (C. S.), J., and Klein (Brett), J., fn. Connecticut General says that while extreme, terminating sanctions are justified when a party has exhibited willfulness, bad faith, and fault. Id. The parties agreed that all motions and the settlement conference should be held on the same date, and counsel for the Sugasawaras sought and obtained an ex parte order that the hearing on each of these matters (the motion to strike Newland's answer, a motion to strike testimony, Newland's summary judgment motion, and the MSC) be held on April 21. Can any country impose sanctions? As for the 21 day Safe Harbor provision the legislature specifically amended California Code of Civil Procedure Section 128.5 on January 7, 2017 to make crystal clear the that the requirement for a 21 day Safe Harbor provision was mandatory and was identical to the requirements that its previous version referred to under California Code of Civil Procedure Section 128.7. [No. at pp. 9 (Subd (d) amended effective January 1, 2007; adopted effective July 1, 2001; previously amended effective January 1, 2004.). Of 9 DOPPES v BENTLEY MOTORS INC California Court of. (Id. The Printed: 2/25/2021 02/25/2021 Motion: Protective Order r ZOlsrerV7283061 Page 1 0f 5 SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA MINUTE ORDER deposition notice shall state all 0f the following, in at least 12-point type: . ********************************* 4. Ninth Circuit Reverses Sanctions for Failure to Consider. However, Defendants request for sanctions is DENIED. Vogel (C. S.), J., and Klein (Brett), J., fn. [1a] The rule is that it is an abuse of discretion for a trial court to issue a terminating sanction for failure to pay the sanction. Sale. Effective immediately we have updated our refund policy! 631] [court "should not deprive a party of all right to defend an action if the discriminating imposition of a lesser sanction will serve to protect the legitimate interests of the party harmed by the failure to provide discovery"].). Plaintiff has not filed an opposition. WebPlaintiff's Opposition to Defendant's Motion for Sanctions | Electronic Frontier Foundation Plaintiff's Opposition to Defendant's Motion for Sanctions of 0 Rule 2.30. 0 ), Caryl Richards has been consistently followed. II. What Is The Fair Claims Settlement Act In California? Note that sanctions under CCP 128.5 and CCP 128.7 are inapplicable to discovery disputes. What Happens When a Lawyer Is Sanctioned Zavieh Law. (See also Morgan v. Ransom (1979) 95 Cal. 51].) The court cited Connecticut General Life Insurance Co. v. New Images of Beverly Hills, which is the authoritative precedent for case-terminating sanctions. existing law or the establishment of new law. Department 53 What to do? WebThis sample motion for sanctions under Code of Civil Procedure section 128.5 in California is filed on the grounds that another party has engaged in bad faith actions or or tactics that are frivolous or solely intended to cause unnecessary delay such as filing numerous frivolous motions or complaints. Upon plaintiff's first motion for terminating sanctions the court found that. 3d 877, 882 [217 Cal. Terminating Sanctions Spell Defeat Against Trade Secret. (a)(1), (b).]) op.). App. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); This field is for validation purposes and should be left unchanged. 215, 220, 17 S. Ct. Filed Supreme Court of the United States. A party's motion for sanctions must (1) state the applicable rule that has been violated, (2) describe the specific conduct that is alleged to have violated the rule, and (3) Let the punishment be equal with the offense. WebSample 1: Motion for Sanctions and Court Order Granting 128.7 Sanctions + Courts Minute Order. [3, 1c] The trial court was in error in concluding that those costs were a matter for appellate court enforcement. They failed to produce discovery, failed to appear in court, violated various court orders, failed on multiple occasions to appear for a deposition, and failed to respond to basic discovery requests. Share what you know and love through presentations, infographics, documents and more. The court on its own motion may issue an order to show cause that must (1) state the applicable rule that has been violated, (2) describe the specific conduct that appears to have violated the rule, and (3) direct the attorney, law firm, party, witness, or other person to show cause why sanctions should not be imposed against them for violation of the rule. San Diego Insurance Coverage Disputes Attorney, Act and Be Damned: The Law on California Punitive Damages, Telephone Death Threats, Unreasonable Drug Tests, and Other Extreme and Outrageous Conduct: Exploring the Intense World of IIED. This was, to say the least, an abuse of discretion by itself. In Jones v. Otero (1984) 156 Cal. For the purposes of this rule, "person" means a party, a party's attorney, a witness, and an insurer or any other individual or entity whose consent is necessary for the disposition of the case.

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