Can attorney pro se litigants be awarded monetary sanctions pursuant to section 128.5?

In reaching this conclusion, we disagree with a case which considered monetary sanctions awarded to attorney pro se litigants pursuant to section 128.5: Abandonato v. Coldren (1996) 41 Cal.App.4th 264, 48 Cal.Rptr.2d 429. Section 128.5 utilizes language similar to section 2023, subdivision (b)(1) in describing the basis of a monetary sanction award: "reasonable expenses, including attorney's fees, incurred by another party." In Abandonato, the Fourth District held that attorneys who represented themselves could be awarded attorney's fees as sanctions under section

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