Excerpt: ...ly against plaintiff Frederick Hart and his attorney, Paymon Hifai, under section 128.5. The basis for the motion is plaintiff's counsel having submitted to the clerk a request to enter defendants' defaults after a stipulated extension to answer or otherwise plead had expired on June 14, 2021, but two days after defense counsel had filed a declaration under section 430.41, subdivision (a). This subdivision requires a meet and confer effort before...