California Court of Appeal May 22, 1991, A049637 (Papadakis v. Zelis)

Opinion

KLINE, P. J.

Appellant Bruce P. Zelis, an attorney litigant appearing pro se, abused the appellate process by prosecuting a frivolous appeal for the purpose of delay. After we dismissed the appeal and indicated we were considering the imposition of sanctions, appellant filed a federal bankruptcy petition and informed us that, as a result, he was invulnerable to monetary sanctions.