California, United States of America
The following excerpt is from Needelman v. Dewolf Realty Co., A141306 (Cal. App. 2015):
It is the "plaintiff's burden to show the reviewing court how the complaint can be amended to state a cause of action." (Michaelian v. State Comp. Ins. Fund (1996) 50 Cal.App.4th 1093, 1105.) Needelman has not provided any explanation for how the foregoing paragraph satisfies the requirements for a bailment contract or what allegations demonstrate a breach or negligent breach of that contract.6
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