What is the test for determining whether a party has failed to produce a court-ordered document?

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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