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Atalaya Funding II v. Barkett CA4/1
William J. Barkett (William) and Lisa Barkett (jointly the Barketts) appeal an order, which (1) denied, in part, motions to quash subpoenas issued by Atalaya Funding II LP (Atalaya) to third party witnesses in connection with a judgment debtor examination to enforce a money judgment against William and related entities, and (2) awarded sanctions against the Barketts and their counsel, David M. Gilmore, pursuant to Code of Civil Procedure section 1987.2. Gilmore appeals only the award of sanctions imposed against him. The Barketts and Gilmore contend the court abused its discretion in awarding sanctions because they had substantial justification for taking the position the third party subpoenas were not authorized by the Enforcement of Judgments Law (§ 680.010 et seq.). We disagree and affirm the order.

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