INDIVIDUAL DEFENDANTS' MOTION FOR SUMMARY ADJUDICATION
TENTATIVE RULING: Each of Plaintiff's Evidentiary Objections is OVERULED.
Defendants' motion for summary adjudication is GRANTED as to the Ninth Cause of Action and DENIED as to all other grounds.
A. Legal Background
The party moving for summary adjudication bears the burden of persuasion that there is no triable issue of material fact. (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 850.) A defendant meets this burden by showing that one or more elements of plaintiff’s cause of action cannot be established, or that there is a complete defense thereto. (Ibid.) The moving party also bears an initial burden of production to make a prima-facie showing of the nonexistence of any triable issue of material fact. (Id. at p. 850-51.) If the party carries this burden, there is a shift and the opposing party is then subjected to a burden of production to make a prima-facie showing. (Ibid.) "In ruling on the motion, the trial court