California, United States of America
The following excerpt is from Datig v. Dove Books, Inc., 73 Cal.App.4th 964, 87 Cal.Rptr.2d 719 (Cal. App. 1999):
Thus, the trial court here has the power, pursuant to rule 227, (as well as under Code Civ. Proc., 575.2), to award plaintiff her attorney fees as sanctions for defense counsel's violations of state-wide and/or local court rules. (Cf. Bauguess v. Paine (1978) 22 Cal.3d 626, 634, 150 Cal.Rptr. 461, 586 P.2d 942.)
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