Cases sanctioning appellant's counsel are uncommon, most of them arising from the pursuit of frivolous appeals. Cases sanctioning a respondent's counsel on appeal, however, are downright rare. Yet one such case recently emerged from the 4th District Court of Appeal, Division Three - Kim v. Westmoore Partners Inc., 2011 DJDAR 17112 (Nov. 20, 2011) - in the context of a default judgment. The case is noteworthy n...
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