In ITT Telecom Products Corp. v. Dooley (1989) 214 Cal. App. 3d 307, an employee executed an express confidentiality agreement, yet later testified as an expert witness against his former employer. The court held that the litigation privilege is inapplicable to an employee's voluntary disclosures made for compensation, rather than for the purposes of litigation, recognizing that by signing a nondisclosure agreement, the employee undertook an obligation similar to the psychotherapist's statutory duty set forth in Cutter v. Brownbridge (1986).