What is the test for imposing discovery sanctions on a party in a personal injury action?

"`. . . In choosing among its various options for imposing a discovery sanction, a trial court exercises discretion, subject to reversal only for manifest abuse exceeding the bounds of reason. . . .'" (Lang v. Hochman (2000) 77 Cal.App.4th 1225, 1244.) In exercising their discretion to impose discovery sanctions, trial courts consider the totality of the circumstances which include the conduct of the party, the willfulness of the dereliction, the degree of detriment to the propounding party, and the number of formal and informal attempts to obtain discovery. (Id ., at p. 1246.) When a party

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