California, United States of America
The following excerpt is from Dohr v. Lintz, G049660 (Cal. App. 2014):
A few courts have permitted clients to file appeals of sanctions awards against both the client and the attorney, liberally construing the notice of appeal to extend to both the client and the attorney, or by reasoning that the appeal has been brought on the attorney's behalf. (See, e.g., Eichenbaum v. Alon (2003) 106 Cal.App.4th 967, 974; Kane v. Hurley (1994) 30 Cal.App.4th 859, 861, fn 4.)
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