MOTION For Judgment On The Pleadings Or, In The Alternative, Partial Judgment On The Pleadings

DENY MOTION FOR JUDGMENT ON THE PLEADINGS. DEFAMATION CAUSE OF ACTION SURVIVES UNDER CCP SECTION 337.20. DOCTRINE OF "YOU CANNOT DEFAME A DEAD PERSON" DOES NOT APPLY.
DENY MOTION FOR JUDGMENT BASED ON COMMUNICATIONS PRIVILEGE. COMPLAINT ALLEGES MALICE.
GRANT MOTION FOR PARTIAL SUMMARY JUDGMENT UNDER CCP 337.34. STRIKE CLAIMS FOR DAMAGES RELATING TO PAIN AND SUFFERING. (302/AJR/AA)