11
the Trust, and Singh, to produce evidence of their financial condition--an order
disregarded by each defendant. A defendant is in the best position to know his or her
financial condition, and cannot avoid a punitive damage award by failing to cooperate
with discovery orders.
A number of cases have held that noncompliance with a court order to disclose
financial condition precludes a defendant from challenging the sufficiency of the
evidence of a punitive damages award on appeal. (See Corenbaum v. Lampkin (2013)
215 Cal.App.4th 1308, 1337-1338; StreetScenes v. ITC Entertainment Group, Inc. (2002)
103 Cal.App.4th 233, 243-244; Mike Davidov Co. v. Issod (2000) 78 Cal.App.4th 597,
600, 606-610; see also Caira v. Offner (2005) 126 Cal.App.4th 12, 40-41; In re Marriage
of Hofer (2012) 208 Cal.App.4th 454, 458-459.) Rawat makes no effort to explain why
these authorities do not apply herein. We find they do, and reject her claim of error.
II
Appeal of Singh
Singh’s briefing flagrantly disregards appellate norms. As we have told him
before, a brief must contain “ ‘meaningful legal analysis supported by citations to
authority and citations to facts in the record that support the claim of error’ ” and contain
adequate record citations, or else we will deem all points “to be forfeited as unsupported
by ‘adequate factual or legal analysis.’ ” (Singh, supra, 227 Cal.App.4th at p. 817.)
Singh once again has filed briefs that either state the facts in the light favorable to
himself, rely on facts unsupported by the record, or make incoherent legal arguments.
However, we discern four issues presented with sufficient clarity to merit discussion.
Any other points “are simply overtaken or outflanked by resolution of the matters which
we do discuss or do not warrant discussion because they are too fragmentary or obscure.”
(Claypool v. Wilson (1992) 4 Cal.App.4th 646, 659; see Tilbury Constructors, Inc. v.
State Comp. Ins. Fund (2006) 137 Cal.App.4th 466, 482.)