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Marriage of Golan and Liu
In this postdissolution case, the wifes attorney challenges two separate sanction orders, one imposing $1,000 in a discovery dispute, the other imposing $3,500 for alleged bad faith conduct involving ex parte applications.
Court conclude that the trial court did not abuse its discretion in imposing the $1,000 sanction because the attorney made baseless objections to discovery. But, in awarding the $3,500, the trial court relied on a statute that has never gone into effect, and the order did not describe any misconduct or explain the courts reasoning. Accordingly, Court affirm the first order and reverse the second.

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