Does the short form pleading rule apply to federal defendants in civil cases?

A criminal defendant has a "federal constitutional right to '"be informed of the nature and cause of the accusation"'" against him. (People v. Quiroz (2013) 215 Cal.App.4th 65, 70, quoting Gray v. Raines (9th Cir. 1981) 662 F.2d 569, 571.) Although California law provides that a person charged as a principal of a crime is automatically deemed to be charged as an aider and abettor as well ( 971; People v. Garrison (1989) 47 Cal.3d 746, 776, fn. 12), the California courts are divided over whether the notice imparted by this "short-form pleading" rule provides adequate notice under the federal constitution. (Compare People

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