Rees

DISCUSSION

A. Standard of Review “The standard of review for summary judgment is well established. The motion ‘shall be granted 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.’ (Code Civ. Proc., § 437c, subd. (c).) A moving defendant has met his burden of showing that a cause of action has no merit by establishing that one or more elements of a cause of action cannot be established or that there is a complete defense. [Citation.] [¶] We independently review an order granting summary judgment, viewing the evidence in the light most favorable to the nonmoving party.” (Lackner v. North (2006) 135 Cal.App.4th 1188, 1196 (Lackner).) B. Crawford Met Burden of Going Forward Rees first argues that Crawford presented insufficient evidence to go forward with her summary judgment motion. She recognizes the shifting burden of production in a motion for summary judgment. “[G]enerally, the party moving for summary judgment bears an initial burden of production to make a prima facie showing of the nonexistence of any triable issue of material fact; if he carries his burden of…