How has the court considered past conduct of an attorney in deciding whether to grant sanctions?

The court's ultimate grant of sanctions was based upon appellants' entire pattern of conduct over the course of the litigation. The court of the eastern [39 Cal.App.4th 1043] division was entitled to consider appellants' earlier behavior, even though the court of the southern division had found the behavior exhibited up to that point did not merit sanctions. In Sabado v. Moraga (1987) 189 Cal.App.3d 1, 234 Cal.Rptr. 249, sanctions were ordered early in the proceedings for a failure to comply with discovery based upon termination of a deposition. Sanctions were ordered again later in the proceedings, based upon the " 'continued difficulty in obtaining timely discovery....' " (Id. at p. 10, 234 Cal.Rptr. 249.) The court reversed the later order: "We agree that if an attorney continues to engage in dilatory tactics to prevent legitimate discovery a court should be able to consider past conduct in considering the attorney's bad faith on the subsequent occasions. Where, however, subsequent conduct is not the type that warrants the imposition of sanctions, past conduct which has already been considered by a court cannot justify the imposition of additional sanctions; otherwise an attorney might be

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