California, United States of America
The following excerpt is from Barton v. Ahmanson Developments, Inc., 17 Cal.App.4th 1358, 22 Cal.Rptr.2d 56 (Cal. App. 1993):
[17 Cal.App.4th 1362] This issue was anticipated by dictum in Slemaker v. Woolley, supra, 207 Cal.App.3d at pp. 1381, 1382, 255 Cal.Rptr. 532. There the court held that a discovery sanction order against an attorney who still represented the party in the underlying suit could not be appealed. The court cautioned that a different result could well be justified if the order involved a party's former attorney. We agree and conclude that in the limited circumstances of this case appellant can appeal the discovery sanction.
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