Laborde

After an unsatisfactory divorce—almost, but not quite, a redundancy—Phillip Laborde sued his wife’s former attorney, Evan L. Ginsburg, and Susan Aronson, the psychologist retained to conduct a custody evaluation in his marital dissolution proceeding. The complaint alleges breach of contract, malpractice, defamation, conspiracy to defame, invasion of privacy, conversion, interference with contract, intentional infliction of emotional distress, and injunctive relief. Aronson prevailed on a motion for summary judgment and the action against Ginsburg was dismissed with prejudice in the face of the same summary judgment motion. The trial court awarded each defendant sanctions pursuant to Code of Civil Procedure section 128.7. Laborde contests the judgments and the sanction award, but we find no error save our own, and therefore affirm.

At some point in the course of the Laborde marital dissolution proceedings, the attorneys handling the matter agreed to retain Dr. Aronson as an Evidence Code section 730 evaluator. Laborde agreed to advance the costs subject to a court ruling apportioning her fees. Evan Ginsburg, the attorney representing Mrs. Laborde, mailed a confirming…