California, United States of America
The following excerpt is from Silkes v. Servicing, B252857 (Cal. App. 2014):
notice of defaultwas false, or that they lacked reasonable ground for belief in the truth of the notice of default. Mere allegations that the statements were "maliciously published" fail to meet the pleading requirements for malice. (Boyich v. Howell (1963) 221 Cal.App.2d 801, 803.)
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