A Generalized Estimate Of Fees Expended On A Discovery Dispute Was Inadequate.
In Marriage of Pair, Case No. F089740 (5th Dist. Jan. 29, 2026) (unpublished), a $3,000 sanctions award against ex-wife and her counsel in a discovery dispute was reversed. It was not reversed on the merits. Instead, it was reversed and remanded because the $3,000 in incurred fees was based on a conclusory declaration statement about an estimate of what was expended by the winning side. The Fifth District said not enough: too conclusory, with some explanation of hourly rates and an accounting of time expended to make sure it related to the discovery misuse issues.