I'm not sure why parties and lawyers repeatedly try to get out of sanctions orders through voluntary dismissals and then arguing that the court "lost" jurisdiction to sanction them given the dismissal. That argument pretty much never works, and rightfully so. It doesn't work here either.
As an aside, the opinion is also a reminder to be super careful when sending out emails; in particular, to make sure that your message doesn't inadvertently include an incriminating e-mail chain. For example, the email here mistakenly included a message on the chain from the father of one of the parties -- himself a trust and estate lawyer in New York -- that said: "I have reviewed [your residence trust] and believe I have a method of indefinitely tying your house up in litigation against [Langer], IN NEW YORK. . . My action may well not succeed, but it would have a very good chance of tying up your house for years—and deterring any would-be buyer who would be off-put 100% from buying a house in litigation, especially in NY.”
Yeah. That's not something you want the court (or the other side) to see. 'Cause it pretty much makes clear that the motivation for the filing of your action wasn't necessarily to actually win.
And that'll get you in trouble. On multiple fronts.
