In what circumstances will a plaintiff be denied leave to amend his third cause of action?

As we have said, to satisfy his appellate burden, plaintiff must show "'in what manner he can amend his complaint and how that amendment will change the legal effect of his pleading.'" (Rakestraw v. California Physicians' Service, supra, 81 Cal.App.4th at p. 43.) To do so, plaintiff must clearly and specifically set forth the applicable substantive law and factual allegations that sufficiently state all required elements of that cause of action in a manner that is "factual and specific, not vague or conclusionary." (Id. at p. 44.) Here, plaintiff has not done so. He has neither identified the elements of a cause of action for an accounting, nor stated with any specificity what facts he could allege to satisfy the elements of his cause of action.³ In short, although plaintiff asserts that he could have amended his complaint "to allege sufficient facts to show that the lender Defendants owe him a sum of money," he has not told us what those facts are or how they give rise to a cause of action for an accounting. Thus, he has not satisfied his appellate burden to show that the trial court abused its discretion by denying him leave to amend the third cause of action.