Petrini v. Simon CA6

CourtCalifornia Court of Appeal
DecidedFebruary 9, 2026
DocketH052200
StatusUnpublished

This text of Petrini v. Simon CA6 (Petrini v. Simon CA6) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Petrini v. Simon CA6, (Cal. Ct. App. 2026).

Opinion

Filed 2/9/26 Petrini v. Simon CA6 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SIXTH APPELLATE DISTRICT

KATRINA P. PETRINI, H052200 (Santa Clara County Plaintiff and Appellant, Super. Ct. No. 22CV396254)

v.

SCOTT SIMON, et al.,

Defendants and Respondents.

Appellant Katrina Petrini was employed by Scott Simon (Simon) and Simon Group Consulting, Inc. (collectively, Defendants), but left to start her own vocational evaluation business. Petrini sued Defendants, alleging Simon defamed her in a letter he sent her after receiving a reference request regarding Petrini and her new business. Petrini also alleged Simon defamed her when he provided a letter of termination to the Employment Development Department (EDD) about her, and when Defendants’ attorney questioned her during a deposition. Additionally, Petrini alleged she was compelled to self-publish the termination letter when she applied for other jobs. Petrini appeals the judgment entered against her following the trial court’s grant of Defendants’ motion for summary judgment. We separately adjudicate the three “counts” in the first cause of action for defamation and conclude summary adjudication of the first count should have been denied because there is a triable issue of material fact as to the existence of malice when Simon published the letter regarding the reference requests, which would preclude the application of the common interest privilege. We also conclude summary adjudication should have been denied as to the second cause of action for coerced self-publication because Defendants failed to meet their initial burden, asserting only that Petrini did not offer evidence that she was compelled to self-publish statements about her termination or her qualifications to any third party. Accordingly, we reverse the judgment, and direct the trial court to reinstate the first count of the first cause of action, and the second cause of action. I. BACKGROUND A. Complaint In March 2022, Petrini filed a lawsuit against Defendants. The complaint set forth causes of action for: (1) defamation per se; (2) coerced self-publication – defamation; (3) commercial disparagement – trade libel; and (4) intentional infliction of emotional distress. Petrini alleged the following: Scott Simon is a licensed marriage and family therapist who has been working as a vocational expert for more than 30 years. Petrini began working for Simon in August 2016 as an office manager. She performed administrative tasks, in addition to proofreading, editing, and issuing vocational evaluation reports for injured workers to be used in workers’ compensation and civil litigation cases. Petrini applied to graduate school in early 2017 to enter the industry as a professional clinician and provide vocational expert work for workers’ compensation and civil litigation cases. She earned a master’s degree in health services administration with a double major in rehabilitation from the University of North Texas. Petrini’s employment contract contained a non-competition clause, but Petrini refused to sign the contract and Simon reduced Petrini’s hours. Petrini filed for benefits with the EDD, but Simon reported to the EDD that Petrini voluntarily reduced her own hours.

2 Petrini eventually opened her own company and began advertising to civil litigation and workers’ compensation attorneys as a vocational expert. Prospective clients contacted Simon for a reference. In response to the reference requests, Simon sent Petrini a letter “informing [Petrini] of what [Simon] was telling prospective employers/clients.” The letter “contained many false statements pertaining to training, duties performed and [Petrini’s] experience with Simon Group Consulting.” In the letter, Simon stated that Petrini “never performed any vocational expert evaluations, [has] never been trained in vocational testing, [or] [r]ehabilitation [c]ounseling, and developed no job placement expertise while working with Simon Group Consulting.” Simon stated he would “repeat the [d]efamatory references to each prospective client and potential employers” and that “he was keeping a list of all [Petrini’s] potential employers/clients who called for a reference.” The message was “published to Tamara Nichols,” Simon’s office manager, and “to a ‘long term referral source’ of [Simon].” Simon “contacted [Petrini’s] business partner and stated that [Petrini] should leave the vocational rehabilitation expert industry.” Petrini also “received phone calls from attorneys repeating [Simon’s] [d]efamatory statements as well as the [EDD].” In addition to the letter regarding the reference requests, Simon had previously sent a termination letter to Petrini on March 25, 2021. The letter falsely accused Petrini of job abandonment and insubordination, which was not true. Petrini had taken paid family leave due to her daughter’s illness and Simon chose to terminate Petrini’s employment rather than have Petrini come back to work. Simon provided the termination letter to the EDD. Petrini filed a workers’ compensation claim due to emotional distress from Defendants’ actions. During a November 2021 deposition, Defendants’ attorney questioned Petrini in a manner that mirrored the language from the June letter regarding the reference requests. This caused Petrini more emotional distress.

3 Petrini needed to seek new employment after her termination. She applied to several job postings, including to one from the County of Santa Cruz, Juvenile Justice Department, and was required to self-publish information regarding her termination. B. Defendants’ Motion for Summary Judgment or, in the Alternative, Summary Adjudication Defendants filed a motion for summary judgment or, in the alternative, summary adjudication.1 In their separate statement of undisputed material facts, they set forth the following facts and evidence: Scott Simon was Petrini’s former employer. On June 11, 2021, Simon wrote a letter to Petrini notifying her of an inquiry his office had received regarding Petrini’s qualifications, advising her of what he could truthfully say about her work for him, and asserting he could not verify her qualifications as a vocational rehabilitation expert. During Petrini’s first four years of employment with Simon, Petrini calendared appointments, sent out appointment letters and transmittals, proofed and invoiced reports, tended to accounts receivable, and other tasks. In Petrini’s final six to nine months of employment, Simon began training her to assist with doing transferable skills vocational evaluations and research for Simon’s reports. During the course of her employment, Petrini never performed a vocational expert evaluation, provided any rehabilitation counseling, or trained in vocational testing. The statement made about Petrini’s qualifications was made solely to Petrini. In her response to Defendants’ separate statement, Petrini disputed all material facts except for the fact that Simon was her former employer. Following a hearing, the trial court issued an order granting Defendants’ motion for summary judgment. The court entered judgment in favor of Defendants. Petrini timely appealed the judgment.

1 Petrini filed her own motion for summary judgment in May 2023, on the ground that Defendants have no “viable defenses.” That motion is not at issue in this appeal.

4 II. DISCUSSION2 A.

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Petrini v. Simon CA6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/petrini-v-simon-ca6-calctapp-2026.