Ouch [pdf file].
This order illustrates one of the dangers of that double-edge sword known as the telephonic hearing. Appearing by telephone is convenient and can save clients significant amounts of money. But because it is easy to tune the telephone conversation out for even just a moment and not hear something—when your email alert displays the new message you just received, for example—bad things can happen.
In this case, the sanctioned attorney did a commendable job in doing what the court ordered. Still, one can’t help but wince a bit and be grateful that it happened to someone else.