McClean

I. FACTUAL AND PROCEDURAL BACKGROUND

McLean worked for Fishman at his law office from February of 2009 until July of 2011, when he terminated her employment. McLean sued Fishman for, among other things, wrongful termination. McLean gave deposition testimony in that action in July of 2012. Several months later, Fishman filed a cross-complaint against McLean. The cross- complaint alleged that McLean had admitted in her deposition to accessing, taking, and/or altering Fishman’s law office’s physical property, intellectual property, trade secrets, client property, and confidential information. The cross-complaint’s first through fourth and sixth causes of action--for conversion, trespass to chattel, invasion of privacy, misappropriation of trade secrets, and Labor Code violations, respectively--relied on McLean’s alleged admissions. The fifth cause of action, for tortious interference with attorney-client contracts and relationships, alleged that McLean had communicated false information to Fishman’s clients after she was fired, which induced them to terminate their relationships with Fishman. McLean filed a special motion, pursuant to section 425.16, to strike the cross-…