California, United States of America
The following excerpt is from D'Ull v. Kaye, B252707 (Cal. App. 2014):
These additional allegations are not sufficient to turn a breach of contract cause of action into one for fraud. Fraud must be pled with specificity; general and conclusory allegations do not meet this standard. (Small v. Fritz Companies, Inc. (2003) 30 Cal.4th 167, 184.) This requirement of pleading with specificity "'"'necessitates pleading facts which "show how, when, where, to whom, and by what means the representations were tendered."'"'" ( Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.)
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