The following excerpt is from Hardisty v. Moore, Case No. 11-cv-01591-BAS(BLM) (S.D. Cal. 2015):
"Because civil conspiracy is so easy to allege, plaintiffs have a weighty burden to prove it." Choate v. Cnty. of Orange, 86 Cal. App. 4th 312, 333 (2000) (citation omitted). There must be proof of "a mutual understanding to accomplish a common and unlawful plan." Id. "It is not enough that [the defendants] knew of an intended wrongful act, they must agreeexpressly or tacitlyto achieve it." Id.
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