We thank reader Kurt Yap for educating us on these two issues.
What happens if you are an in pro per litigant and want to obtain discovery sanctions for the work you did (based on them being akin to attorney’s fees as if the work had been done by a retained outside attorney)? Answer: you can’t based on Argaman v. Ratan, 73 Cal.App.4th 1173, 1175 (1999), where the appellate court held that a party in pro per (although an attorney) cannot be awarded attorney’s fees as a discovery sanction.
What happens if you are an in pro per litigant, defeat an action, and win a CCP section 128.7 motion? Can you get attorney’s fees for winning the sanctions motion? Answer: No, that too was foreclosed in Musaelin v. Adams, 45 Cal.App.4th 512, 514-515, 521 (2009).