Is a defendant liable for aiding and abetting another in the commission of an intentional tort including a breach of fiduciary duty?

"A defendant is liable for aiding and abetting another in the commission of an intentional tort, including a breach of fiduciary duty, if the defendant '"'knows the other's conduct constitutes a breach of duty and gives substantial assistance or encouragement to the other to so act.'"' [Citation.] The elements of a claim for aiding and abetting a breach of fiduciary duty are: (1) a third party's breach of fiduciary duties owed to plaintiff; (2) defendant's actual knowledge of that breach of fiduciary duties; (3) substantial assistance or encouragement by defendant to the third party's breach; and (4) defendant's conduct was a substantial factor in causing harm to plaintiff." (Nasrawi v. Buck Consultants LLC (2014) 231 Cal.App.4th 328, 343.) Unlike liability for a civil conspiracy, a defendant may be liable for aiding and abetting the breach of a fiduciary duty even though the defendant did not itself owe that duty to the plaintiff. (American Master Lease LLC v. Idanta Partners, Ltd. (2014) 225 Cal.App.4th 1451, 1476.)