The plaintiff in Kamalu v. Walmart Stores, Inc. filed a wrongful termination lawsuit against her former employer, claiming that Walmart’s proffered rationale for her termination – that Kamalu misrepresented her work hours – was false. During the litigation, Walmart subpoenaed Kamalu’s cell phone records, and Kamalu moved to quash the subpoena. Finding that records regarding incoming and outgoing cell phone calls, messages and data usages were directly relevant to Walmart’s defense that Kamalu was terminated for misrepresenting work hours, and that Kamalu had no federal or state privacy right in the number, dates, times and durations of calls and texts (as opposed to the content), a federal district court in California ordered that the requested information be turned over to Walmart.