Can a defendant mount a motion to strike a portion of a plaintiff's cause of action seeking punitive damages?

We recognize that in some cases a portion of a cause of action will be substantively defective on the face of the complaint. Although a defendant may not demur to that portion, in such cases, the defendant should not have to suffer discovery and navigate the often dense thicket of proceedings in summary adjudication. We conclude that when a substantive defect is clear [33 Cal.App.4th 1683] from the face of a complaint, such as a violation of the applicable statute of limitations or a purported claim of right which is legally invalid, a defendant may attack that portion of the cause of action by filing a motion to strike. (2 Civil Procedure Before Trial (Cont.Ed.Bar 1994) 31.2, pp. 31-3 to 31-4.) The motion to strike is widely used to challenge portions of causes of action seeking punitive damages. (See, e.g., Grieves, supra, 157 Cal.App.3d at p. 164, 203 Cal.Rptr. 556.) Its use has also been approved in a case where the face of the complaint failed to state facts showing a primary right of the plaintiff and a primary duty of, or wrong committed by, the defendant. (Lodi v. Lodi (1985) 173 Cal.App.3d 628, 631, 219 Cal.Rptr. 116.)