Crawford v JP Morgan Chase Bank (2015) 242 Cal.App.4th 1265. Attorney sued the bank that talked his 79 year old mother into buying a 29 year annuity. The bank took the attorney’s brother’s deposition. At the deposition, the attorney pointed a can of pepper spray at opposing counsel’s face and discharged a stun gun near counsel’s head. HELD: terminating sanctions proper. Courts have inherent authority to dismiss a case for clear and deliberate misconduct, and if no lesser sanction will act as a deterrent.