(Conduct Justified)  Defendant's conduct is justified because it substantively furthers one or more  24 countervailing interests, including but not limited the need to ensure a healthy, safe workplace and  25 conduct an exam within the parameters of industry standard, barring Plaintiffs purported causes of  26 action.  27  / / /  (Estoppel)  Defendant alleges that Plaintiffs Complaint and each purported cause of action  21  therein is barred, in whole or in part, by the doctrine of estoppel.  22  (Failure to State a Cause of Action)  The complaint fails to state facts sufficient to constitute a cause of action against  SECOND AFFIRMATIVE DEFENSE  (Statute of Limitations)  Defendant alleges that Plaintiffs Complaint and each purported cause of action  17 therein are barred, by the applicable statutes of limitation.  18  19  20   (No Disclosure)  No disclosure by Defendant constituted medical information barring Plaintiffs  4 purported causes of action.  5  6  7   (Plaintiff Consented To Release)  Plaintiff consented to the disclosure of information complained of in her complaint,  20 and therefore waived her right to privacy barring her purported causes of action.  21  22  23   22.  24.  3.  CENTRAL DIVISION  12 KRISTINA RAINES,  Case No. 37-2018-00053708-CU-CR-CTL 