California, United States of America
The following excerpt is from Tucker v. Parfet, A133499 (Cal. App. 2012):
"When deciding the amount of sanctions to impose, courts may consider 'the amount of respondent's attorney fees on appeal; the amount of the judgment against appellant; the degree of objective frivolousness and delay; and the need for discouragement of like conduct in the future' [Citation.]" (Keitel v. Heubel, supra, 103 Cal.App.4th at p. 342.)
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