California, United States of America
The following excerpt is from Privato Sec., LLC v. Sidman, H040385 (Cal. App. 2015):
29 Cal.4th at pp. 93-95; but see City of Alhambra v. D'Ausilio (2011) 193 Cal.App.4th 1301, 1307-1308 [City's declaratory relief action arose from a controversy regarding the scope and enforceability of its settlement agreement with the plaintiff employee, not his protected activity].)
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