May 11, 2026
Court of Appeal of the State of California, Second Appellate District, Division Five
The Rule of J.N. et al. v. Jeffrey Goldberg is that a motion for Code of Civil Procedure section 128.7 sanctions must comply with statutory notice requirements by specifying the hearing date in the initial notice of motion to trigger the mandatory 21-day safe harbor period, under circumstances where the superior court's electronic Court Reservation System makes it impossible to obtain a hearing date more than three days in advance but the safe harbor period requires 21 days.