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IN RE THE MARRIAGE OF QUINLAN

Docket No. A041998.

209 Cal.App.3d 1417 (1989)

257 Cal. Rptr. 850

In re the Marriage of ANDREA LAI and PATRICK M. QUINLAN. ANDREA LAI QUINLAN, Appellant, v. PATRICK M. QUINLAN, Movant and Respondent; REGINALD R. ARMANDO, Objector and Appellant.

Court of Appeals of California, First District, Division Five.

April 28, 1989.

Attorney(s) appearing for the Case

COUNSEL

Reginald R. Armando, in pro. per., for Appellants.

Patrick M. Quinlan, in pro. per., for Respondent.

OPINION

KING, J.

(1a) In this case we hold that an order imposing sanctions on an attorney under Code of Civil Procedure section 128.5 cannot be based upon grounds not asserted before its rendition without the attorney having had adequate notice of or opportunity to respond to the threat of sanctions. We also conclude that due process does not necessarily require that a motion for sanctions for alleged misconduct during...

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