Pillsbury, Madison & Sutro v. Schectman

In Pillsbury, Madison & Sutro v. Schectman (1997) 55 Cal.App.4th 1279, the court observed, "Defendant has failed to cite any authority contrary to the foregoing cases condemning self-help evidence gathering by employees for use in contemplated litigation against their soon-to-be former employers. The facts here, involving the wrongful possession of confidential documents for use in anticipated litigation . . . raise an issue distinctly within the court's inherent authority to administer the resolution of disputes, and no policy exception to that authority is presented by this case." ( Id. at p. 1287.)