119 Cal.App.3d 516 (Cal. Ct. App. 1981) Cited 81 times
In Board of Trustees v. Superior Court (1981) 119 Cal.App.3d 516, 531, a defamation action rather than an action arising from employee discipline, the court concluded that confidential written complaints by an employee against another employee fell within the "letters of reference" exclusion in section 1198.5. Given our holding here, we are not required to address defendants' assertion the "letters of reference" exclusion applies to the incident report in question and the identity of the coemployee who complained against Kaye.
