Is there a cause of action for breach of contract, breach of the covenant of good faith and fair dealing or fraud?

The problem with plaintiffs argument is that the complaint contains no facts which would state a cause of action for breach of contract, breach of the covenant of good faith and fair dealing, or fraud. Rather, as set forth above, the complaint merely states that a controversy exists regarding the sums due under the agreement. However, there is no allegation that plaintiffs performed their obligations under the Agreement, nor that defendant breached its obligations; thus, no cause of action for breach of contract is stated. Neither is there any factual allegation which would support a cause of action for breach of the covenant of good faith and fair dealing or fraud. Thus, this is not a case where the complaint alleges "' facts showing a right to some relief . . . but is only defective with respect to the manner or form in which the facts warranting relief have been pleaded.' [Citations.]" (Johnson v. County of Los Angeles (1983) 143 Cal. App. 3d 298, 306, 191 Cal. Rptr. 704.)