The following excerpt is from Partington v. Gedan, 914 F.2d 1349 (9th Cir. 1990):
2 For example, in Cunningham v. County of Los Angeles, 879 F.2d 481, 490 (9th Cir.1988), cert. denied, --- U.S. ----, 110 S.Ct. 757, 107 L.Ed.2d 773 (1990), we held that a district court may not impose Rule 11 sanctions for conduct that occurred "after the signing of the pleadings." In appellate practice, of course, there are no pleadings.
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