In Sherman v. Kinetic Concepts, Inc. (1998) 67 Cal.App.4th 1152, the plaintiffs discovered after trial that the defendant had failed to disclose 21 of 24 prior complaints involving the defective product at issue, despite the plaintiffs' requests for such information during discovery. ( Id. at pp. 1157, 1159.) The trial court ruled that discovery sanctions could not be imposed after trial. ( Id. at p. 1160.) The Court of Appeal reversed, declaring itself "appalled" by the defendant's admission that it had intentionally withheld the information. ( Id. at p. 1162.) The court stated that monetary sanctions under section 2023 were mandated in these circumstances. ( Id. at p. 1163.)