SUBJECT: Motion for Summary Judgment/ Adjudication

Moving Party: Defendants Staples Contract & Commercial, LLC, Staples, Inc., Jeffrey Roman Narlock, and Charisse Clay

Resp. Party: Plaintiff Joyce Allen

The Court GRANTS Defendants’ motion for summary judgment, and in the alternative, summary adjudication.

PRELIMINARY COMMENTS:

During oral argument, Plaintiff’s counsel raised for the first time the argument that Plaintiff’s first cause of action included a retaliation claim under Labor Code §1197.5(k)(1). (See infra, §I(C)(2).) Counsel argued that since this wasn’t addressed in the Motion for Summary Judgment, Defendant’s Motion for Summary Judgment must be denied. Plaintiff’s counsel admitted that they had not raised this issue in their opposition. They stated that the reason it was not raised in the opposition was because they were limited to 20 pages for a Motion for Summary Judgment Opposition. The Court does not accept this argument. Twenty pages is the statutorily-mandated le