Is a motion for summary adjudication a separate and distinct cause of action?

affirmative defense, a claim for damages, or an issue of duty." ( 437c, subd. (f).) "[T]he clearly articulated legislative intent of section 437c, subdivision (f), is effectuated by applying the section in a manner which would provide for the determination on the merits of summary adjudication motions involving separate and distinct wrongful acts which are combined in the same cause of action. To rule otherwise would defeat the time and cost saving purposes of the amendment and allow a cause of action in its entirety to proceed to trial even where, as here, a separate and distinct alleged obligation or claim may be summarily defeated by summary adjudication." (Lilienthal & Fowler v. Superior Court (1993) 12 Cal.App.4th 1848, 1854-1855.) "[R]egardless of how pled in the complaint," the allegation may consist of two separate and distinct causes of action. (Id. at p. 1854.) "[U]nder subdivision (f) of section 437c, a party may present a motion for summary adjudication challenging a separate and distinct wrongful act even though combined with other wrongful acts alleged in the same cause of action." (Id. at pp. 1854-1855.)