$12,500 Was The Sanctions Tab Against A Third-Party Law Firm; $11,517.50 Was The Sanctions Award Against Another Third Party.
We have related sanctions awards to third parties for subpoenas issued by an employee in both Crider v. Pillsbury Winthrop Shaw Pittman LLP, Case No. B342274 (2d Dist., Div. 8 May 29, 2026) (unpublished) and Crider v. GRM Information Mgmt. Servs. of California, Case No. B342639 (2d Dist., Div. 8 May 29, 2026) (unpublished), both authored by Justice Wiley on 3-0 panel opinions.
In the first one, employee lost a motion to quash a subpoena against the Pillsbury law firm. Sanctions of $12,500 were imposed. That award was sustained because there was no reporter’s transcript or settlement statement to show there was an abuse of discretion—inadequate record, put another way. (Also, Pillsbury likely will get attorney’s fees for prevailing on appeal, a trial court determination on remand.)
On the second case, employee did not fare any better as to a different third party. The $11,517.50 sanctions award was affirmed because employee withdrew the subpoena before the hearing on the motion to quash, rendering the motion moot and presumptively showing the sanctions award was proper.