California, United States of America
The following excerpt is from Hellmuth v. Bank of Am., N.A., H042544 (Cal. App. 2017):
Finally, plaintiffs allege that defendants recorded documents to initiate foreclosure proceedings with knowledge of their falsity and with intent to defraud plaintiffs. These conclusory allegations are insufficient to support a fraud claim. "In California, fraud must be pled specifically; general and conclusory allegations do not suffice. [Citations.]" (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.) " 'Thus " 'the policy of liberal construction of the pleadings . . . will not ordinarily be invoked to sustain a pleading defective in any material respect.' " [Citation.] [] This particularity requirement necessitates pleading facts which "show how, when, where, to whom, and by what means the representations were tendered." ' [Citation.]" (Ibid.)
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