In Leeyer v. Pro Circuit Products, Inc., Case No. D059660 (4th Dist., Div. 1 Mar. 19, 2013) (unpublished), an attorney was hit with $6,400 in discovery sanctions under CCP § 2030.030 for not abiding with the terms of a court order regarding the form of a letter sent to defendant’s customers buying a certain motorcycle part involved in the underlying action. Attorney, on appeal, argued that this noncompliance was not expressly enumerated within the list of “misuse of the discovery process” violations, which only dealt with formal discovery requests. That argument was not persuasive to the appellate court, because the misuse “menu list” is only illustrative, not exclusive in nature, and attorney’s noncompliance with a court order in this situation certainly fell within the parameters of conduct which could give rise to sanctions.