California, United States of America
The following excerpt is from Mink v. Encina Veterinary Clinic Inc., A129371 (Cal. App. 2011):
" 'The essential allegations of an action for fraud are misrepresentation, knowledge of its falsity, intent to defraud, justifiable reliance, and resulting damage. [Citation.] Every element of the cause of action for fraud must be alleged in the proper manner and the facts constituting the fraud must be alleged with sufficient specificity to allow defendant to understand fully the nature of the charge made. [Citation.]' [Citations.]" (Curcini v. County of Alameda (2008) 164 Cal.App.4th 629, 649.) "This
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particularity requirement necessitates pleading facts which 'show how, when, where, to whom, and by what means the representations were tendered.' [Citation.]" (Stansfield v. Starkey (1990) 220 Cal.App.3d 59, 73.)
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