In Kozlowsky v. Westminster Nat. Bank (1970) 6 Cal. App. 3d 593, the court held that a defendant who, like Allen, was a director and majority shareholder of a corporation was not entitled to claim the manager's privilege as a matter of law. The court observed that there were no allegations that the individual defendant was a general manager of the defendant bank or that he was authorized to act for the bank in discharging employees. ( Id. at p. 600.) The appellate court reversed a trial court's order sustaining a demurrer to the plaintiff's cause of action for intentional interference with contract relations and allowed the defendant to assert the manager's privilege as a defense. (Ibid.)