INTRODUCTION

In this consolidated action, Defendant Long Beach Unified School District (“LBUSD”) demurs to the 5th, 6th, 7th and 8th causes of action in Plaintiff Margaret Williams’ 3rd Amended Complaint:

1. Breach of Contract

2. Breach of Implied Good Faith Covenant

3. Negligence – Premises Liability

4. Retaliation (Gov’t Code §12653)

5. Strict Liability Ultra hazardous Activity

6. Assault

7. Battery

8. Public Nuisance

9. IIED

10. NIED

ALLEGATIONS

In 2006 Plaintiff Margaret Williams contracted with LBUSD to serve as “Facilities Consultant in charge of overseeing environmental compliance with LBUSD construction sites.” In 2013 she entered a second contract with LBUSD to provide “project management and planning consulting services for the facilities development and planning branch.”

One project was the site of the Newcomb Academy.

In this consolidated complaint she brings suit against the general contractor, Pinner Construction Co., and a sub-contractor, Howard Contractin