What are the consequences of a trial court's imposition of discovery sanctions for abuse of discretion?

We review the trial court's imposition of discovery sanctions for abuse of discretion. " ' "The power to impose discovery sanctions is a broad discretion subject to reversal only for arbitrary, capricious, or whimsical action. [Citations.] Only two facts are absolutely prerequisite to imposition of the sanction: (1) there must be a failure to comply ... and (2) the failure must be willful [citation]." ' " (Vallbona v. Springer (1996) 43 Cal.App.4th 1525, 1545.) Willfulness in this context means a "conscious or intentional failure to act, as distinguished from accidental or involuntary noncompliance."

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