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P0125 Litigants who appear in pro per, including lawyers, who have prevailed on motions to compel responses to requests for production of documents cannot recover attorney fees as a discovery sanction, but can recover reasonable expenses incurred, including photocopying, computer-assisted legal research, and other identifiable and allocatable costs.CitationKRAVITZ v SUPERIOR COURT (Pro Se Sanctions) 91 CA4 1015 [See: CCP 128.5, 2030, 2023; CivC 1717; Trope v Katz 11 C4 274, T/AT 11/95; Abandonato v Coldren 41 CA4 264, T/AT 2/96; Argaman v Ratan 73 CA4 1173, T/AT 9/99]
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