Liu

INTRODUCTION

Dr. Albert Liu, a dentist, sued the Pacific Palisades Dental Group (PPDG) and its principals for breach of contract, quantum meruit, fraud and deceit, Labor Code violations, and other contract-related claims arising out of Liu’s employment with PPDG. Liu appeals from the judgment entered after the trial court imposed terminating sanctions because of Liu’s prelitigation misconduct of furtively obtaining and reviewing attorney- client privileged email communications between PPDG and its attorneys, and testifying falsely about his conduct at an evidentiary hearing. Liu raises four issues on appeal. First, he argues that the trial court erred in imposing terminating sanctions because his misconduct was not so egregious that there was no possibility for a fair trial on the merits with the lesser sanction of disqualifying his counsel. Second, he contends that, because he timely filed a request for dismissal without prejudice of his contract-related claims, the trial court lacked jurisdiction to issue terminating sanctions on those claims. Third, he argues that the trial court exceeded its authority when, in addition to dismissing his claims with prejudice, the court…