This document is an opposition to a motion for judgment on the pleadings filed in a California Superior Court. It was submitted by an attorney on behalf of their client, the plaintiff, to oppose the defendant's motion. The opposition argues that the complaint does state valid causes of action and the defendant's demurrer lacks merit. It includes a brief statement of facts about the underlying lawsuit and causes of action in the original complaint. The memorandum provides arguments for why the motion should be denied under the relevant code of civil procedure.