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Achterkirchen v. Montiel CA1/1
Jesus Montiel appeals from a postjudgment order granting monetary, issue, and evidentiary sanctions against him and his attorney for failure to comply with court orders compelling the production of documents sought pursuant to a subpoena duces tecum. Shortly after judgment was entered against Montiel in the underlying litigation, he recorded a deed of trust in favor of his attorney, Thomas Smurro, against a commercial building Montiel owned. The deed of trust referenced an underlying promissory note to Smurro for $850,000. Creditors subsequently served an order for a debtor’s examination on Montiel, accompanied by a subpoena duces tecum seeking, among other things, the promissory note and related documents.

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