California, United States of America
The following excerpt is from Rau v. PNC Bank, B278898 (Cal. App. 2017):
with the same specificity required in a[n] . . . action for fraud." (Small v. Fritz Companies, Inc. (2003) 30 Cal.4th 167, 184.) Where, as here, fraud or negligent misrepresentation is alleged against a corporation or other collective entity, the plaintiff is obligated to "allege the names of the persons who made the alleged [misrepresentations], their authority to speak, to whom they spoke, what they said or wrote, and when it was said or written." (Tarmann v. State Farm Mut. Auto. Ins. Co. (1991) 2 Cal.App.4th 153, 157.)
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