1118 It is an abuse of discretion for a trial court to issue a terminating sanction for failure to pay a monetary sanction.
NEWLAND v SUPERIOR COURT (Non-payment of Sanctions) 40 CA4 608 [See: CCP 2023; Caryl Richards v Superior Court 188 CA2 300; Midwife v Bernal 203 CA3 57]
No guarantees.
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