Rickman

DISCUSSION

I.

STANDARD OF REVIEW

We review the grant of summary judgment de novo. (Sales v. City of Tustin (2021) 65 Cal.App.5th 265, 271.) “‘A trial court should grant summary judgment “if all the papers submitted show that there is no triable issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” [Citation.] A defendant may establish its right to summary judgment by showing that one or more elements of the cause of action cannot be established or that there is a complete defense to the cause of action. [Citation.] Once the moving defendant has satisfied its burden, the burden shifts to the plaintiff to show

2 Rickman also sued Marker. The parties stipulated to dismiss Marker from the litigation without prejudice.

3 that a triable issue of material fact exists as to each cause of action. [Citation.] A triable issue of material fact exists where “the evidence would allow a reasonable trier of fact to find the underlying fact in favor of the party opposing the motion in accordance with the applicable standard of proof.”’ [Citation.] “‘“We review the trial court’s decision de novo, considering all the evidence set forth in the…