What is the burden of production for a union?

Once the defendant has met its initial burden, the burden of production shifts to the plaintiff. To avoid summary judgment, the plaintiff must come forward with "some significant probative evidence tending to support its complaint." Compton v. Ide, 732 F.2d 1429, 1434 (9th Cir.1984). In order to establish that the union is not entitled to the statutory exemption, the plaintiff must establish that the conduct complained of does not arise out of a labor dispute, that the conduct complained of is not within the language of section 20, or that the conduct is "excepted" from the general protection of the exemption.