California, United States of America
The following excerpt is from Flowers v. Hillyer, A120478, A121941 (Cal. App. 2011):
12. The only other case upon which plaintiffs rely, Hansen v. Sunnyside Products, Inc. (1997) 55 Cal.App.4th 1497, 1503, footnote 1, has no application here. That case does not concern an award of punitive damages or a party's purported failure to produce court-ordered documents.
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