California, United States of America
The following excerpt is from Jansen Associates, Inc. v. Codercard, Inc., 218 Cal.App.3d 1166, 267 Cal.Rptr. 516 (Cal. App. 1990):
An order made pursuant to section 128.5 awarding sanctions against an attorney for a party is appealable because it is a final order on a collateral matter directing the payment of money. (Ellis v. Roshei Corp. (1983) 143 Cal.App.3d 642, 645, fn. 3, 192 Cal.Rptr. 57.)
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