In Youngworth v. Stark (1991) 232 Cal.App.3d 395, the trial court dismissed a case as a sanction for the plaintiffs' counsel's noncompliance with local delay reduction rules. (Youngworth, supra, 232 Cal.App.3d at p. 398.) Counsel missed three court appearances of escalating importance and failed to timely file reports and answers to court-ordered, standardized interrogatories. (Id. at pp. 398-399, 405.) Youngworth concluded that the trial court did not abuse its discretion in dismissing the case. (Id. at pp. 405-406.) Youngworth noted that the plaintiffs' counsel's disobedience wasted time and judicial resources. (Id. at p. 405.) In addition, prior to dismissal, less severe sanctions were imposed (two monetary sanctions), yet counsel's disobedience continued. (Id. at pp. 405-406.) Therefore, the trial "court could reasonably conclude that sanctions less severe than dismissal would be ineffective to obtain counsel's compliance with the local fast track rules." (Id. at p. 406.) In Elkins v. Superior Court (2007) 41 Cal.4th 1337, a family law case, a local rule and a trial scheduling order required parties in dissolution trials to present their respective cases by written declarations in lieu of live testimony. (Elkins, supra, 41 Cal.4th at p. 1344.) In these written trial declarations, parties were required to establish the admissibility of all exhibits they sought to introduce for trial purposes. (Ibid.) In his written trial declaration, Jeffrey Elkins failed to establish the evidentiary foundation for 34 of his 36 exhibits. (Ibid.) Consequently, the trial court excluded them as a sanction for noncompliance, leaving Mr. Elkins with only two exhibits. (Id. at pp. 1344, 1363-1364.) The court proceeded to the merits and divided the marital property in a manner adverse to Mr. Elkins. (Id. at p. 1345.) Mr. Elkins filed a writ petition attacking the local rule and scheduling order, which essentially mandated a "trial by declaration." (Id. at p. 1350.) Elkins concluded that the local rule (and the scheduling order) were inconsistent with various statutory provisions, including the ban on hearsay evidence at trial. (Elkins, supra, 41 Cal.4th at p. 1345.) Elkins also concluded that the trial court "abused its discretion in sanctioning Mr. Elkins by excluding the bulk of his evidence simply because he failed, prior to trial, to file a declaration establishing the admissibility of his trial exhibits." (Id. at pp. 1363-1364.) During its discussion of the sanction issue, Elkins commented: "Although authorized to impose sanctions for violation of local rules (Code Civ. Proc., 575.2, subd. (a)), courts ordinarily should avoid treating a curable violation of local procedural rules as the basis for crippling a litigant's ability to present his or her case. . . . In the absence of a demonstrated history of litigation abuse, 'an order based upon a curable procedural defect including failure to file a statement required by local rule, which effectively results in a judgment against a party, is an abuse of discretion.' " (Elkins, supra, 41 Cal.4th at p. 1364.)