Electronic Universe, Inc. v. Super. Ct. CA2/3
We deem the appeal to be a petition for writ of mandate and grant the relief requested. Reece was self-represented, and his declaration in support of his motion for sanctions failed to show that he incurred any attorney fees or expenses as a consequence of any conduct by Electronic or Smyth. (§ 128.7, subd. (d).) Therefore, the trial court lacked statutory authority to award Reece any monetary sanctions.
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