Carlsen

This is a defendant’s summary judgment case. A summary judgment may be granted a defendant if it is shown that the plaintiff cannot establish one or more elements of his or her cause of action or that there is a complete defense to the claim. (Code Civ. Proc., § 437c, subd. (p)(2).) A defendant’s “burden of production is to show that ‘ “one or more elements of’ the [plaintiff’s] “cause of action” . . . “cannot be established [Citations.] The burden can be satisfied by a showing that ‘the plaintiff does not possess, and cannot reasonably obtain, needed evidence . . . .’ [Citation.] ‘If a plaintiff pleads several theories, the defendant has the burden of demonstrating there are no material facts requiring trial on any of them.’ ” (Teselle v. McLoughlin (2009) 173 Cal.App.4th 156, 162-163 [ 92 Cal.Rptr.3d 696 ] (Teselle).)

Plaintiff Jason Michael Carlsen (Jason) was severely injured from a fall from a cliff above the Sacramento River in Redding. Although he cannot recall how or why he fell, he sued his two companions Sarah Koivumaki (Sarah) and Zachary Gudelunas (Zach), asserting causes of action for assault arid battery, negligence, willful misconduct, and intentional…