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Garvey School Dist. v. Miranda
Jose Mariano Castillo (Castillo), former attorney for defendant Robert Miranda (Miranda), appeals in propria persona an order directing Castillo to pay sanctions in the amount of $10,922.50 to plaintiff and respondent Garvey School District (the District) for filing a frivolous anti-SLAPP motion on Miranda's behalf. (Code Civ. Proc., S 425.16.)
The essential issue presented is whether the trial court abused its discretion in sanctioning Castillo.
the record establishes that irrespective of the unauthorized moving declaration, the moving papers met their burden. Therefore, the anti-SLAPP motion was not frivolous. Accordingly, the order sanctioning Castillo for filing the anti-SLAPP motion reversed with directions.

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