California, United States of America
The following excerpt is from Zimmerman v. Riggs, B225028 (Cal. App. 2011):
10. Tiscareno correctly identifies abuse of discretion as the applicable standard of review with respect to his appeal from the sanctions orders. (Day v. Collingwood (2006) 144 Cal.App.4th 1116, 1130 [award of sanctions under section 128.7 is reviewed for abuse of discretion].)
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