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Filed 4/2/18 Berman v. Angelone CA2/8 NOT TO BE P
Code of Civil Procedure section 2023.010, subdivision (g), allows the imposition of sanctions when a litigant disobeys a court order to provide discovery. The trial court found that the defendants, employing a variety of devices and excuses, failed to obey its order for pretrial discovery and imposed monetary sanctions. The trial court also found that defendants had violated a second order related to a mental health examination of plaintiff. The trial court’s order is unclear as to whether it awarded sanctions for one or both of these violations. Because defendants were not afforded an opportunity to be heard regarding the imposition of sanctions for violating the mental health examination order, the trial court’s sanctions order of December 6, 2016, is conditionally reversed and remanded. If the trial court’s order was intended to impose sanctions solely on the failure to produce documents, the trial court shall reinstate the sanctions order. If the trial court’s order

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