California, United States of America
The following excerpt is from Gee v. Estate of Jewett, 211 Cal.Rptr.3d 137, 6 Cal.App.5th 477 (Cal. App. 2016):
sanctions for a discovery abuse, because such dismissals are the procedural equivalent of a default. (Rodriguez v. Brill (2015) 234 Cal.App.4th 715, 725, 184 Cal.Rptr.3d 265.)
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