Defendant notes that the court in Robertson distinguished Greco but implicitly approved the holding of that case, which Defendant asserts is directly on point. Defendant further asserts that Greco has been followed by a number of district courts in California, including most recently in Walsh v. Frederick J. Hanna Associates, 2010 WL 5394624 (E.D. Cal., December 21, 2010). Defendant requests judicial notice of the Walsh order.