California, United States of America
The following excerpt is from Karimlou v. Aurora Bank FSB, G047190 (Cal. App. 2013):
sustain a fraud cause of action that fails to set forth such specific allegations. (Ibid.) The heightened pleading standard for fraud requires "'pleading facts which "show how, when, where, to whom, and by what means the representations were tendered."' [Citation.]" (Ibid.) Thus, "every element of the cause of action for fraud must be alleged in full, factually and specifically." (Wilhelm v. Pray (1986) 186 Cal.App.3d 1324, 1331.)
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