If, as both parties agree, there are no factual issues related to the applicability of the employment exclusions and that determination can be made as a matter of law, then Moore and Verlander could not possibly have controlled the outcome of that coverage issue through any means, including discovery. Accordingly, they could not possibly have been conflicted in their dual representation of OOIDA and Bordeaux such that they were ever put in the position of having to choose which master to serve. Fed. Ins. Co., 219 Cal. App. 4th at 42. 4 As discussed in OOIDA's Motion for Partial Summary Judgment on the employment exclusions filed on June 22, 2017 (ECF No. 189), OOIDA agrees with Burts that no factual issues exist with regard to those exclusions, but disagrees as to their applicability.