Generally, the amount should reflect what is necessary to redress the ‘undue burden’ a frivolous appeal imposes on the legal system and respondent and to deter the same type of conduct in the future.” (Eisenberg et al., Cal. Practice Guide: Civil Appeals and Writs, supra, ¶ 11:135, p. 11-55, citing Pierotti v. Torian (2000) 81 Cal.App.4th 17, 33; In re Marriage of Stich (1985) 169 Cal.App.3d 64, 78; Hersch v. Citizens Savings & Loan Assn, supra, 146 Cal.App.3d 1002, 1013.) The factors that may be considered in setting the amount of sanctions include the appellant’s net worth (Bank of California v. Varakin, supra, 216 Cal.App.3d at p. 1640; In re Marriage of Stich, supra, 169 Cal.App.3d at p. 78) the need for “discourage[ment of] like conduct in the future” (Pierotti v. Torian, supra, 81 Cal.App.4th at pp. 34-35), and the lack of any discernible deterrent effect of any previous sanction order (Papadakis v. Zelis, supra, 8 Cal.App.4th at p. 1150).
This opinion constitutes a written statement of our reasons for imposing sanctions under Flaherty, supra, 31 Cal.3d at page 654. This appeal shows a disturbing similarity to the facts of previous cases in which the courts have been forced to award sanctions, including one of our prior opinions, In re Marriage of Stich (1985) 169 Cal.App.3d 64, 75-78 [ 214 Cal.Rptr. 919].) In Stich, as here, a determined litigant with no meritorious legal arguments went through a battery of retained lawyers, unfounded disqualification motions aimed at trial judges, and other similar vexatious maneuvers before proceeding in propria persona to prosecute a frivolous appeal for the apparent purpose of harassment.
First, although it is clear respondent court had no obligation to honor real party's request for a statement of decision regarding the denial of petitioner's motion to quash (see Maria P. v. Riles (1987) 43 Cal.3d 1281, 1294 [ 240 Cal.Rptr. 872, 743 P.2d 932]; but cf. In re Marriage of Stitch (1985) 169 Cal.App.3d 64, 76 [ 214 Cal.Rptr. 919] [intimation that statement of decision would be warranted "given the irreconcilable factual conflicts in the declarations submitted in support of and in opposition to [a] motion to quash"]), no authority has been cited for the proposition that the court was powerless to file such a statement. Section 632 and California Rules of Court, rule 232, are directed to situations where a statement of decision is required; they do not limit situations where a statement of decision can be permitted.