INTRODUCTION

Defendant Lindsay Toms demurs to each cause of action in Plaintiff Jammie Hill’s complaint:

1. General & Professional Negligence

2. Int. Infliction of Emotional Distress (“IIED”)

3. Battery

4. Sexual Battery (CC §1708.5)

5. Breach of Fiduciary Duty

6. Sexual Harassment (CC §51.98)

7. Negligence Per Se

8. Sexual Abuse by a Therapist (CC §43.93)

Lindsay Toms concurrently moves to strike:

Paragraphs 37, 43, 50, 57, 64, 75

Causes of Action 5, 7, 8

The Prayer at Paragraphs 3, 4, and the portion of Paragraph 5 at 21:14 “3287, 3288 and”

Defendant Beach City Treatment, LLC (“Beach City”) moves independently to strike the prayer for punitive damages.

ALLEGATIONS

Plaintiff alleges that as of July 2017 he was an alcoholic “in an unstable and toxic relationship” living in Illinois. He decided to “make a change” and moved to California and engaged both Defendant to diagnose and treat him. He checked into a detoxification facility owned by Beach City in Huntington Beach.