Appeal Sanctions, Requests For Admission: Litigant’s Failure To Show Why Costs-Of-Proof Sanctions Were Erroneous Drew Appeal Sanctions Of $32,960.70

We See A Growing Trend Of Appellate Sanctions In Recent Cases.

            Appellant in Knudson v. Ryer, Case No. A149532 (1st Dist., Div. 5 Dec. 17, 2018) (unpublished) failed to show why RFA costs-of-proof sanctions under CCP § 2033.420 should be reversed based on deficient analysis in the appellate briefing. That led the DCA to find the appeal frivolous, assessing $32,960.70 jointly and severally against plaintiff and plaintiff’s counsel and in favor of the respondent—a growing trend if you look at our posts in the last couple of months!