Can an attorney be penalized for advising disobedience?

An attorney may only be penalized under this provision for advising disobedience. It is not enough that the attorney's actions were in some way improper and contributed to the disobedience of the court order. For example, a sanction order against an attorney was held improper where the attorney made no effort to contact his clients concerning their depositions until the day before the date scheduled, with the result that the clients were unavailable and failed to appear. (Andrews v. Superior Court (1960) 183 Cal.App.2d 756, 7 Cal.Rptr. 194.)

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