Zeiny

I. BACKGROUND

A. Factual Background1 Zeiny, originally from Egypt, lives and works in the United States designing nuclear power plants. Since at least September 2009, Zeiny has been under the care of a psychiatrist, Duke Fisher, M.D., for depression. Dr. Fischer’s progress notes from an October 19, 2011 session with Zeiny describe him as “anxious,” “disorganized,”

1 The statement of facts is based on the allegations in the operative first amended complaint and its four exhibits. We “ ‘accept as true both facts alleged in the text of the complaint and facts appearing in exhibits attached to it. If the facts appearing in the attached exhibit contradict those expressly pleaded, those in the exhibit are given precedence.’ ” (Sarale v. Pacific Gas & Electric Co. (2010) 189 Cal.App.4th 225, 245.) “agitated,” and “confused,” and state that Zeiny was experiencing “paranoid ideation in terms of ‘they are watching me.’ ” Zeiny attempted suicide the following day because of what he characterizes as “abuse [by] CIA renegade individuals/unit,” which included “conspiring with his employer to establish pretext to terminate his employment.” Zeiny was hospitalized at Good…