No Abuse Of Discretion Demonstrated.
In re Marriage of Rafipoor, Case Nos. G053243/G053665 (4th Dist., Div. 3 Jan. 18, 2018) (unpublished) involved a situation where ex-husband was assessed with Family Code section 271 sanctions in the amount of $20,000. Among other things, the record suggested that husband made a motion with his finger across his throat while certain witnesses were testifying in court. The appellate court agreed that harassment of witnesses is bad faith conduct hampering cooperation between parties and attorneys for section 271 sanctions purposes. 271 sanctions award was affirmed here based on failure to show the award was an abuse of discretion. Presiding Justice O’Leary authored the 3-0 panel decision.