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Scholz v. Boston Herald
Miller, Kaplan, Arase & Co. (Miller Kaplan) appeals from a $4,500 sanctions order in a discovery dispute originating in Massachusetts, contending the trial court violated its due process rights by failing to inform it what conduct or circumstances justified the imposition of sanctions. It also contends the sanctions order was substantively unsupported by California law. We agree with the first contention, do not reach the second, and reverse the sanctions order.

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