Does a motion seeking attorneys' fees and sanctions for frivolous conduct in a small claims action succeed?

That branch of defendant's motion seeking attorneys' fees is denied as defendant has not demonstrated a basis for any entitlement to such an award. Defendant's request for an order imposing sanctions and directing claimant to pay costs and disbursements is also denied. Costs and sanctions for frivolous conduct in civil litigation are not available "in proceedings in a small claims part of any court" (22 NYCRR 130-1.1[a]; see Spiegel v. Continental Airlines, 11 Misc 3d 145(A), 819 NYS2d 851 [App Term 2d Dept 2006]).