Does a court have jurisdiction to dismiss a dismissal sanction for failure to timely file a joint issue memorandum or other paper satisfying the fast-track rules?

The most recent case, Moyal v. Lanphear (1989) 208 Cal.App.3d 491, at 502-503, 256 Cal.Rptr. 296, reversed a dismissal sanction imposed against a plaintiff for failure of plaintiff's counsel to timely file a joint-issue memorandum or other paper satisfying the San Diego Superior Court's local fast-track rules. Moyal holds the fast-track rules are subject to the section 575.2, subdivision (b) protective exception. It concludes that the provision was violated by imposition of the dismissal sanction without a prior evidentiary hearing determining that the procedural omission was, in fact,

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