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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9II <br />10l <br />11 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />to Code of Civil Procedure section 425.16, will and hereby moves to strike the entirety of Plaintiff <br />FRANCES ROBUSTELLI's ("Plaintiff') Complaint. <br />This motion is based on the grounds that the entirety of Plaintiff's Complaint, including the <br />three causes of action stated therein (for Violation of Labor Code section 1102.5(b), Violation of <br />Labor Code section 1102.5(c), and Gender Discrimination), is based on speech and conduct in <br />furtherance of the right to free speech and free petition. Furthermore, Plaintiff will not be able to <br />demonstrate a likelihood of succeeding on the merits of her claims. <br />PLEASE TAKE FURTHER NOTICE that Defendant also seeks the recovery of its <br />reasonable attorneys' fees incurred in preparing the instant motion pursuant to California Code of <br />Civil Procedure section 425.16(c)(1). <br />This motion is based on the Notice, Memorandum of Points and Authorities, Request for <br />Judicial Notice and all exhibits attached thereto, Declaration of Councilmember Victor Aguilar, Jr. <br />and all exhibits attached thereto, and any and all oral argument the Court may hear in connection <br />with the instant Motion. <br />SPECIAL MOTION TO ST:R1 E <br />Defendant hereby moves to strike all causes of action in Plaintiff's Complaint on the <br />grounds that Plaintiff's causes of action against Defendant are premised on protected activity. As <br />set forth more fully in the points and authorities, all of Plaintiff's claims against Defendant <br />involve speech or conduct in the scope of their protected activities. In addition, because Plaintiff <br />cannot establish a probability of prevailing on her claims, Defendant's motion to strike must be <br />granted. <br />Dated: July 28, 2025 <br />ME <br />LIEBERT CASSIDY WHITMORE <br />Morin I. Jacob <br />Ethan J. Wicklund <br />Attorneys for Defendant CITY OF SAN <br />LEANDRO <br />2 <br />Defendant's Special Motion to Strike Plaintiff's Complaint (Anti-SLAPP) <br />12976111.1 SA213-005 <br />