Employment Litigation · Primary-source case analysis

Williams: PAGA Discovery Is Not Limited to the Employee’s Own Worksite

By Aneeta Mishra and Timothy Chan

Published September 17, 2026

Williams v. Superior Court addressed discovery in a representative Private Attorneys General Act action. The employee sought contact information for other California employees allegedly affected by the same wage-and-hour practices.

Ordinary discovery principles applied

The Court rejected a special rule requiring the plaintiff to establish good cause before obtaining basic employee contact information. Relevance and the ordinary discovery statutes supplied the starting point.

The request was not confined to one store

PAGA authorizes an aggrieved employee to pursue civil penalties for Labor Code violations affecting the employee and other current or former employees. The requested statewide contact information was relevant to identifying witnesses and developing the representative claims.

The plaintiff did not have to prove the case first

The trial court could not condition broader discovery on Williams first sitting for a deposition or producing evidence that the claims had merit. Discovery ordinarily permits a party to obtain information needed to investigate and prove the case.

Privacy required safeguards, not automatic denial

Employee contact information implicates privacy interests, but the Court explained that notice procedures and protective measures can reduce intrusion. The proper response is a proportionate privacy protocol rather than an unsupported geographic bar.

Key takeaways

• Define the alleged Labor Code violations and the affected employee group.
• Request information tied to the representative theory and relevant period.
• Propose notice and protective-order safeguards for employee privacy.
• Do not require a merits showing that the discovery itself is intended to develop.