What is the test for requiring a plaintiff to furnish security in a personal injury action?

The California vexatious litigant statutes "provide[ ] that in any litigation pending in a California court, the defendant may move for an order requiring the plaintiff to furnish security on the ground the plaintiff is a vexatious litigant and has no reasonable probability of prevailing against the moving defendant . . . . If, after a hearing, the court finds for the defendant on these points, it must order the plaintiff to furnish security 'in such amount and within such time as the court shall fix.' [Citation.] The plaintiff's failure to furnish that security is grounds for dismissal." (Shalant v. Girardi (2011) 51 Cal.4th 1164, 1170; see 391.1, 391.3-391.4.)