CPF Vaseo Assocs., LLC v. Gray

*1000Code of Civil Procedure section 128.5 provides the trial court with a mechanism to sanction certain bad faith actions and tactics.1 Pursuant to a former version of that section, the trial court ordered CPF Vaseo Associates, LLC (CPF) and its counsel, John P. Byrne, to pay Bruce W. Gray and Barbara Gray (the Grays) just over $30,000 in fees and costs. Yet a mandatory procedural prerequisite to that award was never fulfilled. The motion requesting sanctions was served and filed on the same day, and no safe harbor period was afforded for CPF and Byrne to correct the challenged conduct. While a…