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Marriage of Katumbusi and Whyte
Appellant Fatima Katumbusi (mother) appeals from a court order sanctioning mother $3,000 under Family Code section 271. On appeal, mother claims she was denied the opportunity to make a record for appeal and denied the opportunity to be heard prior to sanctions being ordered. Mother also claims the trial court wrongly allowed father Frederick Whyte’s attorney to represent him beyond the scope of the attorney’s notice of limited representation, wrongly allowed father to file a modified billing statement hours before the hearing on sanctions, and failed to provide mother with a statement of decision regarding the order of sanctions. Finally, mother claims the order of sanctions imposes on her an unreasonable financial burden in contravention of Family Code section 271. Finding none of mother’s claims to have merit, we affirm.

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