The following excerpt is from Alkayali v. Den Hoed, Case No.: 3:18-cv-00777-H-JMA (S.D. Cal. 2018):
2. "The prerequisite for any action for breach of the implied covenant of good faith and fair dealing is the existence of a contractual relationship between the parties, since the covenant is an implied term in the contract." Smith v. City & Cty. of San Francisco, 225 Cal. App. 3d 38, 49 (1990).
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