What is the appropriate sanction for abuse of discovery?

To determine the sanction best suited to address a particular discovery abuse, the trial court considers such factors as the willfulness of the conduct, the detriment to the propounding party, and the number of formal and informal attempts to obtain the discovery. (Lang v. Hochman (2000) 77 Cal.App.4th 1225, 1246.) The court may impose the sanctions it deems suitable and necessary to enable the party seeking discovery to obtain the objects of that discovery, but may not impose a sanction to punish

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