Haney

*167 Plaintiffs filed a legal malpractice action, then retained a new attorney. The attorney filed a declaration stating that he represented the plaintiffs. A defendant in the action immediately served the attorney with a motion for sanctions under Code of Civil Procedure section 128.7 on the ground that the complaint filed by prior counsel lacked merit. 1 After the motion for sanctions was filed several months later, the trial court granted it. On appeal from the order awarding sanctions, the attorney contends that he was denied the notice and safe harbor required under section 128.7, because the motion served on him did not identify any specific conduct he had taken that violated the statute. We conclude there is no evidence that the attorney presented the complaint to the court within the meaning of section 128.7 before he was served with the motion for sanctions. A *603 new attorney's filing of a declaration merely notifying the court of a change in counsel does not constitute presenting the complaint to the court under section 128.7. We also *168 conclude that a sanctions order cannot be supported solely by evidence of conduct occurring after the motion is served, because a…