Cuevas

FACTS AND PROCEDURAL BACKGROUND

I. Employer Hires Then Fires Former Employee, and

Employee Sues A. Employment relationship Centurion Protection Services (Centurion) is a “private- security firm providing customized protection and bodyguard services to high-profile clients.” Centurion’s CEO is Richard Ray Dudgeon, and its secretary is Tom Rogers. In June 2019, Centurion hired Walter Cuevas as one of its bodyguards. Because Cuevas represented that he had worked as

All further statutory references are to the Code of Civil Procedure unless otherwise indicated. “SLAPP” is short for “strategic lawsuit against public participation.”

2 a firefighter, Centurion “provided him access to its high-profile clientele and paid him at a higher rate of pay to reflect his alleged experience.” As part of his employment, Cuevas executed a nondisclosure agreement that prohibited him from disclosing information regarding Centurion or its clients. Cuevas provided services through Centurion to actor- comedian Kevin Hart and his wife. In November 2020, Centurion learned that Cuevas “had mispresented his experience as a firefighter.” Shortly thereafter, on November 15, 2020, Centurion…