In Aguilar v. Atlantic Richfield Company. (2001) 25 Cal. 4th 826, the Supreme Court undertook to clarify the law courts must apply in California in ruling on motions for summary judgment. Where the motion is brought by a plaintiff, the plaintiff bears the burden of proving each element of the cause of action entitling him to judgment on that cause of action. (Aguilar, supra, 25 Cal.4th at p. 849.) "'Once the plaintiff . . . has met that burden, the burden shifts to the defendant . . . to show that a triable issue of one or more material facts exists as to that cause of action or a defense thereto. The defendant . . . may not rely upon the mere allegations or denials' of his 'pleadings to show that a triable issue of material fact exists but, instead,' must 'set forth the specific facts showing that a triable issue of material fact exists as to that cause of action or a defense thereto.' " ( Aguilar, supra, 25 Cal.4th at 849.) Where the motion is brought by a defendant, the defendant will bear the burden of persuasion that "one or more elements of" the "cause of action " in question "cannot be established," or that "there is a complete defense" thereto. ( Aguilar, supra, 25 Cal.4th at p. 850, citing Code Civ. Proc., 437c, subd. (o)(2).) In Aguilar the Supreme Court established that summary judgment law in California does not require that a defendant conclusively negate an element of the plaintiff's cause of action. Rather, in accordance with federal law, "All that the defendant need do is to 'show that one or more elements of the cause of action . . . cannot be established' by the plaintiff. In other words, all that the defendant need do is to show that the plaintiff cannot establish at least one element of the cause of action -- for example, that the plaintiff cannot prove element X. Although he remains free to do so, the defendant need not himself conclusively negate any such element -- for example, himself prove not X." ( Aguilar, supra, 25 Cal.4th at pp. 853-854, ) In meeting its burden a defendant must present evidence, in the form of affidavits, declarations, admissions, answers to interrogatories, depositions or matters of which judicial notice must be taken. ( Aguilar, supra, 25 Cal.4th at p. 855; Code Civ. Proc., 437c, subd. (b).) In addition to presenting evidence which negates an element of plaintiff's cause of action, "the defendant may also present evidence that the plaintiff does not possess, and cannot reasonably obtain, needed evidence -- as through admissions by the plaintiff following extensive discovery to the effect that he has discovered nothing." ( Aguilar, supra, 25 Cal.App.4th at p. 855, ) Once a defendant has met its burden of showing that a cause of action has no merit, "'the burden shifts to the plaintiff . . .to show that a triable issue of one or more material facts exists as to that cause of action or a defense thereto. The plaintiff . . . may not rely upon the mere allegations of denials' of his 'pleadings to show that a triable issue of material fact exists but, instead,' must 'set forth the specific facts showing that a triable issue of material fact exists as to that cause of action or a defense thereto.' " (Aguilar, supra, 25 Cal.4th at p. 849.) The plaintiff's burden in defeating a motion for summary judgment is only a burden of production and only a burden of making a prima facie showing of a triable issue of fact. (Aguilar, supra, 25 Cal.4th at p. 850.) "A prima facie showing is one that is sufficient to support the position of the party in question." ( Aguilar, supra, 25 Cal.4th at p. 851.) In broadly outlining the law of summary judgment, the Supreme Court stated: "If a party moving for summary judgment in any action . . . would prevail at trial without submission of any issue of material fact to a trier of fact for determination, then he should prevail on summary judgment. In such a case . . . the 'court should grant' the motion 'and avoid a . . . trial' rendered 'useless' by nonsuit or directed verdict or similar device." ( Aguilar, supra, 25 Cal.4th at p. 855.) In Aguilar, the Supreme Court established that summary judgment law in California does not require that a defendant conclusively negate an element of the plaintiff's cause of action. Rather, in accordance with federal law, "all that the defendant need do is to 'show that one or more elements of the cause of action . . . cannot be established' by the plaintiff. In other words, all the defendant need do is to show that the plaintiff cannot establish at least one element of the cause of action -- for example, that the plaintiff cannot prove element X. Although he remains free to do so, the defendant need not himself conclusively negate any such element -- for example, himself prove not X." ( Aguilar, supra, 25 Cal.4th at pp. 853-854.) In meeting its burden a defendant must present evidence, in the form of affidavits, declarations, admissions, answers to interrogatories, depositions, or matters of which judicial notice must be taken. ( Aguilar, supra, 25 Cal.4th at p. 855; Code Civ. Proc., 437c, subd. (b).) In addition to presenting evidence which negates an element of plaintiff's cause of action, "the defendant may also present evidence that the plaintiff does not possess, and cannot reasonably obtain, needed evidence -- as through admissions by the plaintiff following extensive discovery to the effect that he has discovered nothing." ( Aguilar, supra, 25 Cal.4th at p. 855.) Once a defendant has met its burden of showing that a cause of action has no merit, "'the burden shifts to the plaintiff . . . to show that a triable issue of one or more material facts exists as to that cause of action or a defense thereto. The plaintiff . . . may not rely upon the mere allegations of denials' of his 'pleadings to show that a triable issue of material fact exists but, instead,' must 'set forth the specific facts showing that a triable issue of material fact exists as to that cause of action or a defense thereto.' " ( Aguilar, supra, 25 Cal.4th at p. 849.) The plaintiff's burden in defeating a motion for summary judgment is only a burden of production and only a burden of making a prima facie showing of a triable issue of fact. ( Aguilar, supra, 25 Cal.4th at p. 850.) "A prima facie showing is one that is sufficient to support the position of the party in question." ( Id. at p. 851.) In broadly outlining the law of summary judgment, the Supreme Court stated: "If a party moving for summary judgment in any action . . . would prevail at trial without submission of any issue of material fact to a trier of fact for determination, then he should prevail on summary judgment. In such a case . . . the 'court should grant' the motion 'and avoid a . . . trial' rendered 'useless' by nonsuit or directed verdict or similar device." ( Aguilar, supra, 25 Cal.4th at p. 855.) The California Supreme Court described a moving party's summary judgment burdens as follows: "From commencement to conclusion, the party moving for summary judgment bears the burden of persuasion that there is no triable issue of material fact and that he is entitled to judgment as a matter of law. That is because of the general principle that a party who seeks a court's action in his favor bears the burden of persuasion thereon. There is a triable issue of material fact if, and only if, the evidence would allow a reasonable trier of fact to find the underlying fact in favor of the party opposing the motion in accordance with the applicable standard of proof. . . . 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 production, he causes a shift, and the opposing party is then subjected to a burden of production of his own to make a prima facie showing of the existence of a triable issue of material fact. . . . A prima facie showing is one that is sufficient to support the position of the party in question. " (Fns. omitted, see Kids' Universe v. In 2 Labs (2002) 95 Cal.App.4th 870, 877-878.) We review the trial court's decision to grant the summary judgment motion de novo. (Johnson v. City of Loma Linda (2000) 24 Cal.4th 61, 65, 67-68; Sharon P. v. Arman, Ltd. (1999) 21 Cal.4th 1181, 1188, disapproved on another point in Aguilar v. Atlantic Richfield Co., supra, 25 Cal.4th at p. 853, fn. 19.)