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devoid of merit. [Citation.] An order awarding attorneys’ fees
pursuant to section 128.5, as incorporated in section 425.16,
subdivision (c), is reviewed under the abuse of discretion test.
[Citation.] A ruling amounts to an abuse of discretion when it
exceeds the bounds of reason, and the burden is on the party
complaining to establish that discretion was abused.” (Gerbosi v.
Gaims, Weil, West & Epstein, LLP (2011) 193 Cal.App.4th 435,
450; see also Estate of Gilkison (1998) 65 Cal.App.4th 1443, 1448-
1449 [collecting cases and describing the standard of review].)
In its written ruling imposing sanctions (see § 128.5, subd.
(c)), the trial court made clear it was aware of the correct
standard. The court stated, “A determination of frivolousness
requires a finding [that] . . . ‘“any reasonable attorney would
agree such motion is totally devoid of merit.’” Accordingly, we
presume the trial court applied the correct standard in ruling on
the motion for sanctions. (See Denham v. Superior Court (1970) 2
Cal.3d 557, 564 [“[I]t is settled that: ‘A judgment or order of the
lower court is presumed correct . . .’”]; Axis Surplus Ins. Co. v.
Reinoso (2012) 208 Cal.App.4th 181, 190 [“we presume that the
trial court applied the correct standard”].)
For the reasons explained ante, at pages 7-11, the trial
court did not exceed the bounds of reason in finding that any
reasonable attorney would agree that appellants’ anti-SLAPP
motion was “totally and completely without merit.” (§ 128.5,
subd. (b)(2).) The eleventh cause of action for unlawful
retaliation arose from the claim for retaliation in violation of
Civil Code section 1942.5, subdivision (d). It did not arise from
respondents’ allegations that, in retaliation for filing the original
complaint in the present action, appellants had filed a malicious
prosecution action against respondents. “Given the continuous