What is the burden of proving a plaintiff's claim can be cured by amendment to their pleading?

amend, 'we decide whether there is a reasonable possibility that the defect can be cured by amendment: if it can be, the trial court has abused its discretion and we reverse; if not, there has been no abuse of discretion and we affirm. [Citations.] The burden of proving such reasonable possibility is squarely on the plaintiff. [Citation.]' [Citation.] A plaintiff may show for the first time on appeal how amendment would cure the complaint's defects. [Citation.]" (Id. at pp. 740-741.) It is the plaintiff's burden to enumerate the facts he could add to cure existing defects in his pleading to establish a viable claim. (Das v. Bank of America, N.A. (2010) 186 Cal.App.4th 727, 734.)

"'To determine the statute of limitations which applies to a cause of action it is necessary to identify the nature of the cause of action, i.e., the "gravamen" of the cause of action.' [Citation.] The nature of the cause of action and the primary right involved, not the form or label of the cause of action or the relief demanded, determine which statute of limitations applies. [Citations.]" (Carter v. Prime Healthcare Paradise Valley LLC (2011) 198 Cal.App.4th 396, 412.)