Kravitz

Under the Civil Discovery Act of 1986, the trial court must impose monetary sanctions against anyone engaging in conduct that is a misuse of the discovery process, and must order the abuser to pay the reasonable expenses, including attorney’s fees, incurred by anyone as a result of that conduct. Under Trope v. Katz (1995) 11 Cal.4th 274, 277 [ 45 Cal.Rptr.2d 241 , 902 P.2d 259 ], a pro se lawyer cannot recover attorney’s fees under Civil Code section 1717. Under Abandonato v. Coldren (1995) 41 Cal.App.4th 264 , 268 [ 48 Cal.Rptr.2d 429 ], a pro se lawyer can be awarded attorney’s fees as sanctions under Code of Civil Procedure section 128.5. Under Argaman v. Ratan (1999) 73 Cal.App.4th 1173, 1175 [ 86 Cal.Rptr.2d 917 ], a pro se lawyer cannot be awarded attorney’s fees as a discovery sanction.

From these inconsistent rules, we distill this wholly inadequate solution for all pro se litigants—including pro se lawyers—who have prevailed on *1017 motions to compel responses to requests for production of documents: A pro se litigant cannot recover attorney’s fees as a discovery sanction, but he can recover the “reasonable expenses” he has “incurred,” including photocopying,…