Champion/L.B.S. Associates Development Co. v. E-Z Serve Petroleum Marketing, Inc.

Opinion

SILLS, P. J.

In Greene v. Amante (1992) 3 Cal.App.4th 684 [4 Cal.Rptr.2d 571], this court held that orders imposing discovery sanctions over $750 are appealable. In the present appeal, we must decide whether sanctions of less than that amount arising out of one discovery motion may be “aggregated” with sanctions arising out of another motion and decided at the same hearing. For appealability purposes, we believe we must look to the offending lawyer’s course of conduct, not the number of motions involved or the fortuity that they were consolidated for hearing. Here, the course of conduct…