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P0805 A trial court violated due process of four defendants by entering a default judgment against them as a terminating sanction for discovery abuse when two of the defendants had not received notice that the trial court might impose a terminating sanction, a third defendant was not named in any motion to compel discovery or discovery order, and an order directing the fourth defendant to appear through counsel with documents in hand did not refer to sanctions of any type.CitationSOLE ENERGY v HODGES (Ex Parte Sanctions) 128 CA4 199 [See: CCP 2023; Miranda v 21st Century Ins 117 CA4 913, P/AT 5/04
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