Cyber Exploitation – Distribution of Private Sexually Explicit Materials in California

On September 16, 2021, Pentz filed a First Amended Complaint for (1) Stalking; (2) Trespass; and (3) Distribution of Private Materials (Revenge Pornography) Civ. Code section 1708.85. Pentz alleges, among other things, in his Complaint that Auguste stalked Pentz online, showed up at his residence uninvited and repeatedly sent sexually explicit photographs and videos of Pentz to his friends and family.

of sexually explicit materials.

On September 16, 2021, Pentz filed a First Amended Complaint for (1) Stalking; (2) Trespass; and (3) Distribution of Private Materials (Revenge Pornography) Civ. Code section 1708.85. Pentz alleges, among other things, in his Complaint that Auguste stalked Pentz online, showed up at his residence uninvited and repeatedly sent sexually explicit photographs and videos of Pentz to his friends and family.

On September 16, 2021, Pentz filed a First Amended Complaint for (1) Stalking; (2) Trespass; and (3) Distribution of Private Materials (Revenge Pornography) Civ. Code section 1708.85. Pentz alleges, among other things, in his Complaint that Auguste stalked Pentz online, showed up at his residence uninvited and repeatedly sent sexually explicit photographs and videos of Pentz to his friends and family.

of sexually explicit materials (against Johnson).

of sexually explicit materials (against Johnson).

of sexually explicit materials (against Johnson).

Code, § 1708.85, subd. (f)(1) [plaintiff in action for nonconsensual distribution of sexually explicit materials may proceed under pseudonym]; Code Civ. Proc., § 372.5 [allowing pseudonym for guardian ad litem litigating on behalf of a minor]; Civ. Code, § 3427.3 [allowing pseudonym in actions for interference with access to health care]; Cal. Rules of Court, rule 8.401(a) [providing for anonymity in juvenile appeals].)

Sixth Cause of Action for Violation of Civil Code § 1708.85 Defendant demurs to the sixth cause of action for distribution of private explicit materials in violation of Civil Code § 1708.85 on the grounds that Rangels conduct fell outside the scope of employment and that Civil Code § 1708.85 allows for liability only against persons, not entities. As discussed, whether Rangels conduct was within the scope of employment is a question of fact.

Code § 1708.85(f)(1) [allowing plaintiff who sues for intentional distribution of sexually explicit materials without consent to proceed under pseudonym]; Doe v. Lincoln Unified School Dist. (2010) 188 Cal.App.4th 758, 766 [citing cases where party used fictitious name to protect privacy interest].)

of sexually explicit materials.

Code § 1708.85(a).) However, there shall be no liability if the distributed material was previously distributed by another person. (Civ. Code § 1708.85(c)(6).) In this case, the FAC claims that Nair, who Plaintiff shared the alleged content with, admitted that he shared the intimate content with several individuals, including Defendant Corbett who shared the content with additional people. (FAC ¶¶ 9, 12.)

Civil Code § 1708.85(f)(1) provides that a Plaintiff in a civil proceeding for violation of that section may exclude their true name and other identifying characteristics from the court record. More specifically, Civil Code § 1708.85(f)(2)(C) directs that all court orders shall be worded so as to protect the name or other identifying characteristics of the plaintiff from public revelation.

Both sections address the illegal distribution of explicit materials, while Section 1708.86 is focused on digitally altered depictions. Review of the legislative history behind the enactment of Section 1708.85 reveals it was enacted, in large part, in response to the rise of “revenge porn,” the posting of nude or sexually explicit photographs or videos of people online without their consent, even if the photograph itself was taken with consent.

The Motion (ROA # 83) of Plaintiff Jane Doe ("Plaintiff") for a modification of injunction regarding use of Plaintiff's true name in subpoenas, pursuant to Civil Code 1708.85(f), and a continuance of trial and related dates, based on the requirements of the Revenge Porn Statute, Code of Civil Procedure 1708.85(f) which requires all documents filed, served, and used in discovery to use a pseudonym for Plaintiff, will be HEARD.

Based on these allegations, Plaintiff asserts causes of action for (1) negligence; (2) intentional infliction of emotional distress; (3) negligent infliction of emotional distress; (4) public disclosure of private facts; (5) distribution of private sexually explicit materials (CCP §1708.85); and (6) civil conspiracy. Defendants now demur to each cause of action. The primary argument made by Defendants is that each cause of action is barred by the litigation privilege of Civil Code §47(b).

Violation of Civil Code § 1708.85 Upon amendment, Plaintiff has now stated a claim for violation of Civil Code section 1708.85.

This case arises out of the viewing and dissemination of sexually explicit photos of Plaintiff from Plaintiffs phone by Melissa Hammond, Robert Ruiz, Matt Lents, (collectively, the Individual Defendants). During an investigation into overtime compensation, CHP obtained Plaintiffs mobile phone. While searching Plaintiffs phone, Ruiz and Lentz discovered sexually explicit photos of Plaintiff. Ruiz and Lentz shared these photos with Hammond.

Johnson alleges claims for Violation of Penal Code § 502 (Comprehensive Computer Data and Access Fraud Act) , Distribution of Private Sexually Explicit Materials , Public Disclosure of Private Facts against all Third-Party Defendants , Intrusion into Private Affairs , Negligence and Intentional Infliction of Emotional Distress. This hearing is on Plaintiffs special motion to strike the cross-complaint, pursuant to Code Civ. Proc. §425.16(e )(1) .

In the original litigation the jury found defendant violated of Civil Code §1708.85 on August 25, 2017. Here, it is undisputed that plaintiff served defendant with a deposition notice on September 1, 2020, setting defendant's deposition for October 15, 2020.

Code §1708.85, a plaintiff may proceed under a pseudonym, and other parties must redact identifying characteristics from court filings so as to prevent public revelation of plaintiffs identity. Cal. Civ. Code §1708.85(f)(1)-(2). Doe argues the opposition violates §1708.85(f)(1) by including her name, lawsuits in which she is involved and other identifying characteristics.

(c) There shall be no liability on the part of the person distributing material under subdivision (a) under any of the following circumstances: (1) The distributed material was created under an agreement by the person appearing in the material for its public use and distribution or otherwise intended by that person for public use and distribution.

Defendant is really attacking the pleading for failure to state a cause of action for violation of Civil Code § 1708.85 and the Unruh Civil Rights Act[1]. However, a motion to strike may not be utilized as a demurrer: Preliminarily, we note a motion to strike is generally used to reach defects in a pleading which are not subject to demurrer. A motion to strike does not lie to attack a complaint for insufficiency of allegations to justify relief; that is a ground for general demurrer. (Warren v.

On August 22, 2023, Plaintiff filed his Second Amended Complaint (SAC) for (1) Defamation, (2) Libel, (3) Slander, (4) Intentional Infliction of Emotional Distress (IIED), (5) Civil Code § 1708.85, and (6) Negligence against Defendant Cordoba.

Plaintiff argues that the application suggested by Defendant is outside the holding of Kapellas , which regarded unflattering reporting on family related matters – not the distribution of illegally distributed sexually explicit material depicting a candidate.

On August 22, 2023, Plaintiff filed his Second Amended Complaint (SAC) for (1) Defamation, (2) Libel, (3) Slander, (4) Intentional Infliction of Emotional Distress (IIED), (5) Civil Code § 1708.85, and (6) Negligence against Defendant Cordoba. On April 18, 2023, Defendant Cordoba filed her First Amended Cross-Complaint (Cross-Complaint) for (1) Sexual Battery, (2) Intentional Misrepresentation, (3) Concealment, (4) Negligent Misrepresentation, (5) Negligence, and (6) IIED against Plaintiff and ROES 1-35.

Code, § 1708.85, subd. (f)(1).) Defendants acknowledge that section 1708.85 expressly permits Plaintiffs to maintain their anonymity. Nevertheless, Defendants advance several grounds in support of the requested relief, none of which have merit. The plain language of Section 1708.85 is sufficient response to Defendants motion. However, the court will address two points raised by Defendants.

(c) There shall be no liability on the part of the person distributing material under subdivision (a) under any of the following circumstances: (1) The distributed material was created under an agreement by the person appearing in the material for its public use and distribution or otherwise intended by that person for public use and distribution.

On August 22, 2023, Plaintiff filed his Second Amended Complaint (SAC) for (1) Defamation, (2) Libel, (3) Slander, (4) Intentional Infliction of Emotional Distress (IIED), (5) Civil Code § 1708.85, and (6) Negligence against Defendant Cordoba.

Plaintiff filed his operative First Amended Complaint (FAC) on 5/14/21 alleging eleven causes of action: 1) negligence; 2) negligent supervision; 3) negligent hiring/retention; 4) negligent failure to warn, train, or educate; 5) constructive fraud; 6) breach of fiduciary duty; 7) intentional infliction of emotional distress (IIED); 8) gender violence;1 9) commercial sexual exploitation of a minor; 10) constructive invasion of privacy; and 11) distribution of sexually explicit materials. *** Defendant, Johnson

Sections 1708.5-1708.9 are about sexual battery, domestic violence, harassment, invasion of privacy, distribution of sexually explicit photos and video, and preventing entrance into a school or health facility. No such act is alleged in the complaint, and these sections are completely irrelevant to this case.

Sections 1708.5-1708.9 are about sexual battery, domestic violence, harassment, invasion of privacy, distribution of sexually explicit photos and video, and preventing entrance into a school or health facility. No such act is alleged in the complaint, and these sections are completely irrelevant to this case.

Plaintiff asserts that even when distribution is arguably speech, distribution is nevertheless distinct from speech. The Court finds that the gravamen of Plaintiff’s Complaint against Defendant constitutes protected activity under Sections 425.16(e)(3) and (4). As correctly noted by Plaintiff, the gravamen of her Complaint against Defendant is Defendant’s distribution of Plaintiff’s intimate images.

To be blunt, the case revolves around a sexually explicit video, which wife claims husband stole from her computer and then used to blackmail her. Both parties are highly educated medical doctors. The complaint was filed July 18, 2016. ROA 1. There were profound problems with the initial filing, as plaintiff's counsel initially failed to comply with CRC 2.550. The court eventually worked out these issues. ROA 9-14. The defendant husband answered the complaint. ROA 30.

Tokyo Villa avers that the only statute that would allow Plaintiff to use a pseudonym is Civil Code 1708.85, which provides, in relevant part, that: (a) A private cause of action lies against a person who intentionally distributes by any means a photograph, film, videotape, recording, or any other reproduction of another, without the other’s consent...

Code § 1708.85(c)(6).) Defendant asserts that this factual admission is fatal not only to Plaintiff’s claim of conspiracy against Messina, but also to any concept that he could have liability for the underlying tort he is claimed to have conspired to commit. Defendant contends that similarly fatal to a revenge porn claim against Defendant is the fact that there can be no liability under California Civil Code § 1708.85(c)(4) when the “distributed material constitutes a matter of public concern.”

BACKGROUND On June 25, 2021, Plaintiff Marchel Gabrielle Auguste (Plaintiff or Auguste) filed a Complaint (the Auguste Lawsuit) against Defendant Thomas Wesley Pentz (Defendant or Pentz), alleging causes of action for (1) Sexual Battery; (2) Gender Violence; (3) Violation of the Ralph Civil Rights Act; (4) Violation of the Tom Bane Civil Rights Act; (5) Action Based on Civil Code § 1708.85; (6) Intentional Intrusion Into Private Affairs; (7) Battery; (8) Assault; (9) Defamation; (10) Intentional Infliction

Code §1708.85 and IIED, alleging defendant distributed private or intimate photographs of plaintiff without her consent while the parties were in a relationship. Defendant demurs to the claim for IIED.

Code § 1708.85(a) [A private cause of action lies against a person who intentionally distributes by any means a photograph, film, videotape, recording, or any other reproduction of another, without the others consent & (emphasis added)]; Civ.

Analysis (1) Violation of Civil Code § 1708.85 Defendant moves for summary adjudication on this cause of action on the grounds that Timmons did not distribute explicit photographs of Plaintiff and that Defendant is not vicariously liable for violation of Civil Code § 1708.85 because Timmons acted beyond the scope of his employment.

Plaintiffs Complaint alleges causes of action: (1) violation of Civil Code § 1708.85; (2) violation of common law right of publicity; (3) defamation per se; (4) defamation per quod; (5) intentional interference with existing and prospective economic relations; and (6) negligent interference with existing and prospective economic relations. Defendant now moves to dismiss Plaintiffs Complaint for lack of jurisdiction.

On August 22, 2023, Plaintiff filed his Second Amended Complaint (SAC) for (1) Defamation, (2) Libel, (3) Slander, (4) Intentional Infliction of Emotional Distress (IIED), (5) Civil Code § 1708.85, and (6) Negligence against Defendant Cordoba. On April 18, 2023, Defendant Cordoba filed her First Amended Cross-Complaint (Cross-Complaint) for (1) Sexual Battery, (2) Intentional Misrepresentation, (3) Concealment, (4) Negligent Misrepresentation, (5) Negligence, and (6) IIED against Plaintiff and ROES 1-35.

See, e.g., Civil Code §1708.85. Petitioner does not meet any of these criteria. He is on the DOJ’s child abuse index and seeks to get off it. He cites no statute which requires that his identity remain confidential. No exceptional circumstances exist that are highly sensitive and personal to him, such as sexual assault victim or HIV status. The injury Petitioner seeks to avoid will not be incurred by disclosure of his identity. He already is on CACI.

Code § 1708.85). The statute does not, however, disfavor jury trials in actions brought under that section or otherwise limit a defendant’s constitutional right to a jury trial. The Court is sympathetic to Plaintiff’s argument that she is attempting to protect her minor children from additional exposure to media coverage regarding the revenge porn claims by seeking to have those claims tried as a bench trial. Perhaps that argument will ultimately prevail upon Defendant.

Plaintiffs claims in this action stem from Defendants alleged involvement in the production and distribution of the Romeo & Juliet film. Defendant has provided authority showing the production and distribution of a film constitute protected activity under the First Amendment.

Plaintiff recently filed the operative Second Amended Complaint on February 14, 2023, alleging causes of action for Intrusion of Private Affairs, Public Disclosure of Private Facts, Distribution of Private Sexual Material, Negligence, Negligent Infliction of Emotional Distress, Intentional Infliction of Emotional Distress, Defamation Per Se, Defamation Per Quod, and Negligence Per Se.

Plaintiff Fidel Torres (“Torres”) was employed by Defendant D/T Carson Enterprises (“Carson Enterprises”) from March 6, 2018 to August 10, 2018 as a mechanic’s helper and welder. alleges that co-worker, Steven Young (“Young”) made sexually explicit comments and gestures to Plaintiff due to his perceived orientation. Plaintiff asserts that he complained to human resources (HR) and his direct supervisor about the alleged harassment, but no preventative action was taken.

Code §1708.85(a).) “A plaintiff in a civil proceeding pursuant to subdivision (a), may proceed using a pseudonym …” (Id. at (f)(1).) Plaintiff does not allege a cause of action under Civil Code section 1708.85, nor are there any allegations of the distribution of materials covered by this statute. Accordingly, it is inapplicable to the current matter.

Code § 1708.85(f)(1) [pseudonym permitted in suit against person who distributes photos, films, etc. of plaintiff's intimate body parts].) Even in the absence of a statute, anonymity for parties may be granted when necessary to preserve an important privacy interest. ( DFEH v. Superior Court (2022) 82 Cal.App.5th 105, 110.)

On August 22, 2023, Plaintiff filed his Second Amended Complaint (SAC) for (1) Defamation, (2) Libel, (3) Slander, (4) Intentional Infliction of Emotional Distress (IIED), (5) Civil Code § 1708.85, and (6) Negligence against Defendant Cordoba. On November 13, 2023, Defendant Cordoba filed her Answer.

Code §§ 1708.85, subd. (f)(1), 3427.3; Code Civ. Proc. § 372.5; Cal. Rules of Court, rule 8.401(a).) In the absence of a statute, anonymity for parties may be granted when necessary to preserve an important privacy interest. (Doe v. Lincoln Unified School Dist. (2010) 188 Cal.App.4th 758, 766.) “[A]llowing a party to litigate anonymously impacts the First Amendment public access right.

. § 372.5s provision of anonymity in actions concerning nonconsensual distribution of sexually explicit materials. Even where no statute provides for anonymity, California courts have frequently granted permission to proceed anonymously where it is necessary to preserve an important privacy interest. (See Doe v. Lincoln Unified School Dist. (2010) 188 Cal.App.4th 758 [teacher could proceed anonymously in action against school district].)

Plaintiffs Complaint asserts the following causes of action: (1) Negligence and Gross Negligence; (2) Negligent Hiring, Supervision, Retention; (3) Violation of Civil Rights; (4) Invasion of Privacy; (5) Intentional Infliction of Emotional Distress; (6) Premises Liability; (7) Distribution of Sexually Explicit Materials; (8) Negligent Infliction of Emotional Distress; and (9) Sexual Harassment On October 13, 2025, Defendant AIRBNB (Airbnb) filed the Subject Motion

The operative First Amended Complaint (FAC) filed on March 4, 2024, asserts the following causes of action: (1) unlawful distribution of intimate photographs; (2) use of likeness; (3) violation of Performers Rights Act of the United Kingdom; (4) Civil Code 1708.85(a); and (5) 15 U.S.C. § 6851(b). On December 2, 2024, Paramount filed a motion for attorneys fees (the Paramount Motion). On February 14, 2025, Paramount filed a reply in support.

On September 19, 2024, Plaintiff filed a Third Amended Complaint(TAC) alleging the following causes of action: (1) Discrimination under Education Code § 66251, 66252, 66270, 66294.2 against LMU; (2) Discrimination in Violation of the Unruh Civil Rights Act against LMU; (3) Breach of Contract against LMU; (4) Negligence against Michael Mozilo and Does 50-99; (5) California Civil Code § 1708.85 Revenge Porn Statute against Michael Mozilo and DOES 50-99; (6) Intentional Infliction of Emotional Distress against

Code §1708.85(b) creates a private cause of action against a person who intentionally distributes material that exposes an intimate body part of another person without that persons consent. This cause of action is based on allegations that defendants, without consent, took pictures of Doe while she was partially clothed. Defendants argue the SAC does not allege distribution of these photos or facts showing liability for Olson, the HOA or LBPM.

Code §1708.85(b) creates a private cause of action against a person who intentionally distributes material that exposes an intimate body part of another person without that persons consent. This cause of action is based on allegations that defendants, without consent, took pictures of Doe while she was partially clothed. Defendants argue the SAC does not allege distribution of these photos or facts showing liability for Olson, the HOA or LBPM.

Code § 1708.85. On August 20, 2018, the church member Defendants filed an anti-SLAPP motion, which Plaintiffs did not oppose. On August 21, 2018, the church Defendants filed their own anti-SLAPP motion, which Plaintiffs opposed. On September 12, 2018, the court granted both anti-SLAPP motions, struck the complaint, and ordered the action dismissed with prejudice. On October 5, 2018, Defendants filed the instant attorney fee motion. On January 25, 2019, Plaintiffs filed an opposition.

The SAC alleges (1) negligence (against the District); (2) negligent hiring, retention & supervision (against the District); (3) common law invasion of privacy (against Riden); (4) Constitutional invasion of privacy (against the District); (5) Constitutional Invasion of Privacy (against Riden); (6) violation of Civil Code 1708.85 (against Riden); (7) intentional infliction of emotional distress (IIED) (against Riden); and (8) (erroneously

Sections 1708.5-1708.9 are about sexual battery, domestic violence, harassment, invasion of privacy, distribution of sexually explicit photos and video, and preventing entrance into a school or health facility. No such act is alleged in the complaint, these sections are completely irrelevant to this case, and they should not have been included in the complaint.

On July 8, 2024, Plaintiff filed a Second Amended Complaint (SAC) alleging the following causes of action: (1) Discrimination under Education Code § 66251, 66252, 66270, 66294.2; (2) Discrimination in Violation of the Unruh Civil Rights Act ; (3) Education Code Section 220; (4) Negligence against Loyola Marymount University; (5) Breach of Contract; (6) Negligence against Michael Mozilo and Does 50-99; (7) California Civil Code § 1708.85 Revenge Porn Statute; (8) Intentional Infliction of Emotional Distress;

Code § 1708.85, [t]hough no court has yet addressed the applicable statute of limitations, it is likely the three-year statute of limitations applies which governs [a]n action upon a liability created by statute , other than a penalty or forfeiture. [CCP § 338(a)]. ( Cal. Prac. Guide Civ. Pro. Trial Claims and Def. Ch. 2(XII)-D.) The SAC alleges Plaintiff discovered the revenge porn in the spring of 2020. The Complaint was filed in December 2021.

On July 8, 2024, Plaintiff filed a Second Amended Complaint (SAC) alleging the following causes of action: (1) Discrimination under Education Code § 66251, 66252, 66270, 66294.2; (2) Discrimination in Violation of the Unruh Civil Rights Act ; (3) Education Code Section 220; (4) Negligence against Loyola Marymount University; (5) Breach of Contract; (6) Negligence against Michael Mozilo and Does 50-99; (7) California Civil Code § 1708.85 Revenge Porn Statute; (8) Intentional Infliction of Emotional Distress;

While there are no facts supporting BYC’s assumption that the phone calls were prank “hang up” calls, it is not clear what the harassing calls entailed, e.g. sexually explicit language, slurs, etc. As such, it is not clear that the harassment reaches the level of extreme and outrageous misconduct.

Code, § 1708.85, subd. (f)(1) [“A plaintiff who proceeds using a pseudonym and excluding or redacting identifying characteristics as provided in this section shall file with the court and serve upon the defendant a confidential information form for this purpose that includes the plaintiff's name and other identifying characteristics excluded or redacted.”].)

Code §1708.85(b). Plaintiff pleads no facts establishing existence of any such image(s). The only allegation is that defendant requested an explicit video of plaintiff twerking. Compl., para. 22. Plaintiff does not allege the contents of the video, that she was nude or underdressed and does not allege the video was shared. This is insufficient; SUSTAINED with 15 days leave to amend.

Tri-Modal Distribution Services, Inc. (2021) 11 Cal.5th 918, 933.) Defendants contend that Plaintiff fails to state a prima facie case for quid pro quo sexual harassment because there is no evidence that Madueno or Gerardo “proposed an exchange of sexual favors for a job perk.” However, Plaintiff contends that when she asked for a raise, Gerardo responded, “you don’t even know how to ask for it.” (Opp., Plaintiff Decl., ¶ 12, 38.)

Tri-Modal Distribution Services, Inc. (2021) 11 Cal.5th 918, 933.) Defendants contend that Plaintiff fails to state a prima facie case for quid pro quo sexual harassment because there is no evidence that Madueno or Gerardo “proposed an exchange of sexual favors for a job perk.” However, Plaintiff contends that when she asked for a raise, Gerardo responded, “you don’t even know how to ask for it.” (Opp., Plaintiff Decl., ¶ 12, 38.)

Tri-Modal Distribution Services, Inc. (2021) 11 Cal.5th 918, 933.) Defendants contend that Plaintiff fails to state a prima facie case for quid pro quo sexual harassment because there is no evidence that Madueno or Gerardo “proposed an exchange of sexual favors for a job perk.” However, Plaintiff contends that when she asked for a raise, Gerardo responded, “you don’t even know how to ask for it.” (Opp., Plaintiff Decl., ¶ 12, 38.)

Bolanos also reported RUVALCABA’s harassing behavior to MELENDEZ, her former Supervisor and the Location Manager or Location Office Administrator in the Distribution Department. (PRDSS 14-18; PUMF 40, 43-51). On one occasion, RUVALCABA helped Plaintiff put boxes in a car, and RUVALCABA smacked Plaintiff’s rear end on their way back to the warehouse. (PRDSS 11-13; PUMF 34.)

The FAC alleges the following causes of action: (1) Discrimination under Education Code § 66251; (2) Discrimination in Violation of the Unruh Civil Rights Act ; (3) Education Code Section 220; (4) Negligence against Loyola Marymount University; (5) Breach of Contract; (6) Negligence against Michael Mozilo and Does 50-99; (7) California Civil Code § 1708.85 Revenge Porn Statute; (8) Intentional Infliction of Emotional Distress; and (9) Injunctive Relief.

On August 22, 2023, Plaintiff filed his Second Amended Complaint (SAC) for (1) Defamation, (2) Libel, (3) Slander, (4) Intentional Infliction of Emotional Distress (IIED), (5) Civil Code § 1708.85, and (6) Negligence against Defendant Cordoba. On November 13, 2023, Defendant Cordoba filed her Answer.

Code, § 1708.85 (p. 12) On July 18, 2018, Defendant Archbishop filed this motion to disqualify. On August 1, 2018, Plaintiffs filed an opposition. On August 6, 2018, Defendant Archbishop filed a reply. Relevant Background Information In April 2017, Ralph M. Rios emailed Father Clarke’s (using Clarke’s Archdiocese’s email address), accusing him and the Archdiocese of sending emails to parishes that adversely affected Together in Christ, and accusing Clarke of defaming Cailan and Together in Christ.

The FAC alleges the following causes of action: (1) Discrimination under Education Code § 66251; (2) Discrimination in Violation of the Unruh Civil Rights Act ; (3) Education Code Section 220; (4) Negligence against Loyola Marymount University; (5) Breach of Contract; (6) Negligence against Michael Mozilo and Does 50-99; (7) California Civil Code § 1708.85 Revenge Porn Statute; (8) Intentional Infliction of Emotional Distress; and (9) Injunctive Relief.

The overwhelming majority of FFP’s mission is carried out through receipt and distribution of GIK. FFP uses cash donations to procure, ship, and distribute tractor-trailer loads of food, medicines, medical supplies, clothing, and other supplies.

The overwhelming majority of FFP’s mission is carried out through receipt and distribution of GIK. FFP uses cash donations to procure, ship, and distribute tractor-trailer loads of food, medicines, medical supplies, clothing, and other supplies.

Code, § 1708.85 Anti-SLAPP motions to strike complaint On August 20, 2018, Defendants Jonna Malabanan, Natividad Inocencio, Rose Leano (“Parishioners”) filed their special motion to strike. On August 21, 2018, Defendants Father Ramon Valera, Father James Clarke, Father Alex Aclan, and the Roman Catholic Archbishop of Los Angeles (“Church” defendants) filed their special motion to strike. On August 31, 2018, Plaintiffs filed an opposition to the Church Defendants’ motion.