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2694 REVIEW GRANTED Evidence Code sections preserving the confidentiality of mediation do not prevent a mediator from reporting to the court on the conduct of parties and attorneys in connection with a motion for sanctions; a trial court's sanction order must be accompanied by a written order reciting in detail the conduct or circumstances justifying the order.CitationFOXGATE v BRAMALEA (Mediation Sanctions) 78 CA4 653 [See: CCP 128.5; EvC 1115 - 1128; 580 Folsom v Prometheus 223 CA3 1; Rinaker v Superior Court 62 CA4 155]
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